Day 070 - 20 Dec 94 - Page 30


     
     1        employees' equivalent of that, I do find uninviting.  So,
     2        what I am still searching for is some little row which
     3        gives a modicum of information apart from just a total
     4        figure for the year, but avoids having to have discovery of
     5        large numbers of that kind of document.
     6
     7   MR. MORRIS:  I would expect the Plaintiffs to have computer
     8        printouts of accident statistics on a regular basis.
     9
    10   MR. JUSTICE BELL:  Let us see what is produced upon further
    11        enquiry.
    12
    13   MS. STEEL:   Dr. Gomez Gonzalez, a number of times in his
    14        evidence, referred to carrying out audits on suppliers and
    15        suppliers doing audits of slaughterhouses, which he said he
    16        would be entitled to look at and get copies of.  We would
    17        submit that the Plaintiffs should have to disclose copies
    18        of these audits for 1989 or 1990 or, if those years are not
    19        available, then the nearest available year to those years.
    20
    21        He also referred to extra pages of specifications in terms
    22        of animal welfare in relation to the meat product
    23        specifications.
    24
    25   MR. JUSTICE BELL:  Were the audits the ones where we had a table
    26        of shortfalls with a percentage at the end?  They were
    27        inspections, some scheduled and some unscheduled.  That was
    28        a different topic, was it not?
    29
    30   MR. RAMPTON:  My Lord, that is different.  That is by the FSIS,
    31        I think.  What we have is an English version (a sample
    32        only) of a McKey audit form.  That has already been
    33        disclosed.  We will ask the Americans whether they have
    34        anything similar in their possession and, if so, to produce
    35        it.
    36
    37        There is in the documents that Dr. Gomez Gonzalez was able
    38        to obtain while he was still here -- I do not know whether
    39        it is called an audit form or not, I think it is very
    40        likely is -- for example, a Tyson broiler supervisor
    41        report, which is more or less devoted entirely to the
    42        welfare of the chickens.  It is a detailed document.  It
    43        may be the sort of thing that Dr. Gomez Gonzalez was
    44        talking about.
    45
    46   MS. STEEL:   I think in this country and in the USA the
    47        Plaintiffs' witnesses have referred to audits or
    48        inspections being carried out.  They are relying on them to
    49        claim that they are concerned about the welfare of
    50        animals.  I think we are entitled to see what those forms 
    51        in actual fact show in terms of what the results were, not 
    52        just what the questions asked were. 
    53
    54   MR. JUSTICE BELL:  Have you any idea of what volumes are
    55        involved?
    56
    57   MS. STEEL:   In this country, I think Mr. Rampton said there
    58        were, was it, about eight slaughterhouses supplying them,
    59        or something like that -- six; then there would be
    60        Sun Valley as well.  Then, I think, in America -- yes,

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