Day 294 - 05 Nov 96 - Page 28
1 bullet points. But I can see how there has become common
2 ground in the case as the case has gone on up to the point
3 of cooking to a great degree.
4
5 Anyway, we are saying that the risks with minced meat and
6 chicken products are not just inevitable risks to do with
7 the eating of food, or even the eating of meat products,
8 they are particularly risks associated with those kind of
9 products, produced in that kind of system, the production
10 diseases of animals, the slaughter house conditions, the
11 cross-contamination that occurs in the making of the
12 chicken products, which is accepted, that the salmonella
13 burden goes from one percent to 25 percent in the
14 processing factory in the chickens and the minced meat
15 production, because of the bulking of the meat which
16 guarantees the contamination is spread throughout all the
17 product, and it is not on the surface. It is ground up to
18 be present in the interior of the product. Hence, it makes
19 the system in the stores that much more fragile.
20
21 So the point that we want to put over is that McDonald's
22 choose to sell the type of products produced in such a way
23 at all stages as to... that they are the type of products
24 that are most risky if the contamination -- they are most
25 risky in any event as they arrive in the store, and on top
26 of that, of course, if there is any lapse in that fragile
27 cooking then the risk from that product is even greater,
28 which does not apply with most food products. Most food
29 products do not carry a risk if they are not cooked
30 properly.
31
32 Most vegetable products, most grain products, most kind of
33 all kinds of range of products, we are talking about the
34 most risky products that are identified with food poisoning
35 incidents, such as chicken and minced meat. I think that
36 is all defamatory of the Plaintiffs and established beyond
37 any reasonable doubt in this case. In that the riskiness
38 of the product is compounded and magnified because of the
39 production methods that are being used that are inevitable
40 to create that kind of volume and speed of supply at the
41 cheap prices which they need.
42
43 MR. JUSTICE BELL: Yes.
44
45 MR. MORRIS: Right. I think I expressed my point there.
46
47 So going back to showing how some of the particular
48 production problems magnify the risk, for example, Timothy
49 Chambers expressed concern over the widespread use of water
50 sprays in abattoirs to clean carcasses because they merely
51 spread bacteria around. He said he would also be concerned
52 about what he called health risks from any batch of tested
53 meat containing over five million bacteria per gram.
54
55 And then we came on to David Walker. David Walker
56 explained how McKey sampled and tested supplies to McKeys,
57 beef supplies, characterising them as satisfactory,
58 passable and unsatisfactory. Unsatisfactory related to
59 beef which had a total of more than 10 million bacteria per
60 gram and then admitted that such consignments were not in
