Day 095 - 02 Mar 95 - Page 38


     
     1
     2   Q.   Is this basically, as you understand it, the official?
     3        A.  Yes, it is.
     4
     5   Q.   Yes.  I do not know whether we need to go through it in
     6        that case.  Would it help if you just identify some
     7        particular paragraphs?
     8
     9   MR. JUSTICE BELL:  Now that I know that it is accepted that it
    10        is the appropriate document, all I suggest is -- is there
    11        anything in it which you would suggest contradicts
    12        something which Dr. Gomez Gonzalez has said?
    13
    14   MR. MORRIS:  Yes.  OK.  Very briefly, if we just -- by the way,
    15        page 8 did not come through from the fax machine.  That is
    16        why page 8 is missing.
    17
    18   MR. JUSTICE BELL:  We will pick that up later.
    19
    20   MR. MORRIS:  Yes, I did not get that.  First of all, the
    21        critical, major and minor categories, if you look at page 2
    22        point A at the top, are classified as deficiencies, are
    23        they not?
    24        A.  Yes.
    25
    26   Q.   If you look in point C deviation?
    27        A.  Yes.
    28
    29   Q.   A deviation under category C is something that is less than
    30        a deficiency, yes, a departure from an approved system or
    31        programme where no deficiency is found still can qualify as
    32        a deviation?
    33        A.  Yes, starting with "a departure from", yes.
    34
    35   Q.   So for something to be classified it would mean on that
    36        chart we saw before, the form we saw form before, it would
    37        have to be more than a deviation to be classified as a
    38        deficiency; that is obvious.  If you turn over the page to
    39        page 3 and we look at the bottom of the page, point 2?
    40        A.  Page 3?
    41
    42   Q.   Yes, page 3 at the bottom, the last paragraph, the second
    43        sentence: "It should be understood that conditions may
    44        sometimes exist that are less than perfect yet
    45        acceptable".
    46        A.  Yes.
    47
    48   Q.   So it is not about classifying anything that is not
    49        perfect, is it, this system?
    50        A.  That is correct.  There is nothing perfect in nature. 
    51 
    52   Q.   Yes, but if it is imperfect it does not qualify either as a 
    53        deviation or as a more serious deficiency necessarily, does
    54        it?  You said that they were concerned only with perfection
    55        and nothing is perfect?
    56        A.  No.  You are getting it totally wrong.  This document
    57        is different from what we talked about.  We have been
    58        talking about the evidence that you provided ----
    59
    60   Q.   Tysons?

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