Day 085 - 08 Feb 95 - Page 59


     
     1        in and saw we that we had taken all reasonable precautions,
     2        then maybe we could resolve the matters with them more
     3        quickly.
     4
     5   Q.   That was the concern of the company, the reason why they
     6        brought these things in?
     7        A.  I do not know.  In 1991, as I say, I was only
     8        operations manager.  I am trying to give you my
     9        interpretation a few years on from my experience in recent
    10        times.
    11
    12   Q.   The paragraph underneath, "The calibrations must be checked
    13        every morning either (1) for breakfast stores when you
    14        change the main menu or (2) for non-breakfast stores before
    15        you open."  So at that time it was only necessary to carry
    16        out the calibration checks once a day?
    17        A.  That is right.  At that time we were doing calibration
    18        checks as per the calendar and that did not specify a
    19        particular time of day that you did it.  That was a change
    20        of procedure.
    21
    22   Q.   So it has improved since then?
    23        A.  Our documentation has improved.  I do not think there
    24        has been a fundamental change in the checking.  It is just
    25        that we are better at documenting it.
    26
    27   Q.   But it takes place more frequently now?
    28        A.  Yes, we do internal temperature checks four times a
    29        day, whereas before we relied on checking the equipment,
    30        temperature and time, visual checks.
    31
    32   MR. JUSTICE BELL:  How many times are you doing that a day now?
    33        A.  We still do visual checks throughout the day, the
    34        things we train people to do to check that the product is
    35        fully cooked.
    36
    37   Q.   I understand the product but this is a calibration check,
    38        and Ms. Steel is suggesting that if you look at the third
    39        paragraph up from the bottom of the page it was saying it
    40        should be done once a day, the calibration check?
    41        A.  Yes.
    42
    43   Q.   Leave aside the temperature of the product, how many times
    44        a day is it done now?
    45        A.  It is just done as the preventative maintenance
    46        calendar suggests and replaced, checking the equipment by
    47        checking the product.  So the same end is served but by
    48        what we think is an improved method, if that is clear.  On
    49        a daily basis we sought to check ----
    50 
    51   Q.   I am getting confused now because I thought that was 
    52        related to the number of seconds cooking? 
    53        A.  Calibration is the calibrated temperature and the time
    54        when you talk about calibrations.  So you are checking the
    55        equipment to see that the temperature is reading correctly
    56        and if you have a timer and it says 42 seconds, it is 42
    57        seconds.
    58
    59   Q.   But how many times a day now do you actually check the
    60        calibration of ----

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