Day 093 - 28 Feb 95 - Page 70
1 Q. So they would have stopped the entire plant,
2 presumably ---
3 A. Yes.
4
5 Q. -- at that stage?
6 A. Yes.
7
8 Q. On that day?
9 A. That is correct.
10
11 Q. How many times do you know of the entire plant being closed
12 down by the US DA, the Tysons Arkansas plant?
13 A. None.
14
15 Q. Does not Tysons inform you about hygiene problems with its
16 plant?
17 A. Yes, it does.
18
19 Q. But they do not tell you about such severe problems that
20 would result in the plant being closed down?
21 A. If they close the plant, we obviously would know.
22
23 Q. So in this case, in June 1993, you were not informed or, as
24 far as you know, the plant did not close down?
25 A. The plant has not been closed down at any time up to
26 1992.
27
28 Q. Even though 95 per cent of the tests on equipment
29 disassembly proved to be not conforming to -----
30 A. No, you are getting it wrong. That is not what I mean.
31
32 MR. RAMPTON: My Lord, I have difficulty about this. Mr. Morris
33 keeps making assertions about the true interpretation of
34 the meaning of this document. As far I am aware, he is no
35 evidence at of what it actually ----
36
37 MR. MORRIS: I am relying on the witness's definition which was
38 non-conformity.
39
40 MR. JUSTICE BELL: Yes, but we do not know non-conformity with
41 what.
42
43 MR. MORRIS: I just said "non-conformity".
44
45 MR. JUSTICE BELL: But that may not get you very far or it may
46 get you far, it may not -- I can see the figures for
47 myself.
48
49 MR. MORRIS: Yes.
50
51 MR. JUSTICE BELL: What I do not know is what kind of feature
52 the inspector has to see on equipment disassembly to say
53 there is a minor noncompliance there, or a major
54 noncompliance there, or a critical noncompliance there.
55 I just do not know what they are. It appears that the
56 witness does not know what they are either.
57
58 MR. MORRIS: I am relying on the witness's definition of the
59 bringing in the actual scoring would be non-conformity.
60 Whether it is minor, major or critical -----
