Day 093 - 28 Feb 95 - Page 67


     
     1   Q.   Critical comment?
     2        A.  Corrective action.  That is -- yes.
     3
     4   MR. MORRIS:  These tests, if you look at the column on the left
     5        of what was being tested, conditions, surfaces, hand wash
     6        available, volume, adequacy, product, recondition -- I do
     7        not know what that would mean -- toilets available, some of
     8        those would be important hygienic considerations, would
     9        they not?
    10        A.  Yes.
    11
    12   Q.   They are not trivial matters -- I do not know about the
    13        volume?
    14        A.  There are things that are more important to others,
    15        obviously.
    16
    17   Q.   If we move to the next one which is on 53, "Sanitation of
    18        facilities and equipment/personal hygiene".  It says here,
    19        the first one, do you know what "trained employees" mean,
    20        the first one?
    21        A.  Yes.
    22
    23   Q.   What does that mean, that they have training?
    24        A.  Yes.
    25
    26   Q.   According to that, they have a 74 per cent failure rate on
    27        that subject out of 93 tests.  62 -----
    28
    29   MR. JUSTICE BELL:  You had better not say "failure" rate because
    30         -----
    31
    32   MR. MORRIS:  Non-conformity.
    33
    34   MR. JUSTICE BELL:  Yes, that is better.
    35
    36   MR. MORRIS:  62 out of 93 had major non-conformity and six had
    37        critical non-conformity; would that be something that
    38        concerned you?
    39        A.  No.
    40
    41   Q.   It would not?  This is the US DA who, you say, are
    42        responsible for monitoring your process plants?
    43        A.  That is correct.
    44
    45   Q.   They are saying they are not conforming with their
    46        standards?
    47        A.  What they said, what this is saying is that they took
    48        some corrective actions.  It could have been that your
    49        glove is not cleaned properly; it could mean that any
    50        similar things like that, you forgot a glove here, you left 
    51        it on the floor or you dropped it on the floor, or it could 
    52        be anything of those cases.  What this means -- let me 
    53        finish -- what this means is that he took corrective
    54        action, some kind of a corrective action.
    55
    56   Q.   Yes, but you cannot train employees in 10 minutes, can you?
    57        A.  I am not saying -- that is not what it says.
    58
    59   MR. JUSTICE BELL:  That is what I was hoping might be asked.  Do
    60        you know what "trained employees" means, what the

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