Day 111 - 30 Mar 95 - Page 46


     
     1        to be done fairly regularly to serve a purpose at all.  If
     2        it is done as a random sample every now and then, it does
     3        not really -- I do not know what it could be used for.  If
     4        it is used once a month, for example, you are in a
     5        situation where you could be asked:  "Well, what kind of a
     6        purpose does this serve?"
     7
     8        It tells you about the situation on that day of the month
     9        at that time, but it does not tell about the general.  It
    10        should not be used in that sort of a manner.  When
    11        I suggested that we would start using TVC monitoring at
    12        Jarretts, I had in my mind the fact that during my visible
    13        examination of the inspection of the plant, and knowing
    14        what was going on in the plant, I suspected whether the
    15        cleaning could be effected.  There was not enough time for
    16        it and there was no drying allowed.  Obviously, I want to
    17        start monitoring the situation before I condemned it.
    18
    19   Q.   It might be helpful if you actually have the documents in
    20        front of us?
    21
    22   MR. JUSTICE BELL:  Yes.  Do you want the Jarrett file?
    23
    24   MR. MORRIS:  Yes.
    25
    26   THE WITNESS:  There is one file here.
    27
    28   MR. JUSTICE BELL:  It is a file which has "Jarrett" on it.  It
    29        is quite a thin one.
    30
    31   MR. MORRIS:  If we go to the section starting on page 67 which
    32        continues until page 86, yes?
    33        A.  Yes.
    34
    35   Q.   Here we see some, effectively, monthly checks.  I believe
    36        the evidence from McDonald's witnesses is this is when the
    37        checks were done monthly?
    38
    39   MR. RAMPTON:  No, there is no evidence about that one way or
    40        another; it is an assumption made from the documents.
    41
    42   MR. MORRIS:  Assumption by McDonald's witnesses.
    43
    44   MR. RAMPTON:  No, an assumption made by Mr. Morris.
    45
    46   MR. MORRIS:  I thought Mr. Bennett assumed that.
    47
    48   MR. JUSTICE BELL:  It is an assumption I am asked to make from
    49        the fact that I have in front of me a document like this
    50        coming about every month.  In fact, the first one is 23 
    51        days after the first, and is still in March, if I remember 
    52        correctly, but then it is late April, late May, and so on. 
    53        So I will be invited in due course to infer from that there
    54        are monthly checks.
    55
    56   MR. MORRIS:  You were not aware of any swab testing?
    57        A.  No.  I asked particularly about surface swabbing tests
    58        being done.
    59
    60   Q.   To be done?

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