Day 081 - 31 Jan 95 - Page 18


     
     1        say:  "It was estimated that somewhere in the region of 0.2
     2        to 0.3 per cent of birds were dead on arrival".  Is that
     3        what you were told by Sun Valley?
     4        A.  Yes, yes.
     5
     6   Q.   You did not check any records?
     7        A.  No.
     8
     9   MR. JUSTICE BELL:  I remember reading that but could you give me
    10        the page again?
    11
    12   MS. STEEL:  It is page 470 of the bundle, page 2 internally.
    13
    14   MR. MORRIS:  It is the first full paragraph, fourth line.
    15
    16   MS. STEEL (To the witness):  You have mentioned in the same
    17        paragraph towards the bottom that you asked about the
    18        number of birds per crate, and that that number was varied
    19        to allow for difference in sizes so as to prevent
    20        over-crowding; is that relevant to hygiene?
    21        A.  Not particularly for hygiene.  That was not the reason
    22        I was enquiring.
    23
    24   Q.   In the third paragraph -- actually, the fourth if you
    25        include the two lines at the top, I think that is a
    26        separate paragraph?
    27        A.  Yes.
    28
    29   Q.   You have mentioned about hand washes and eye wash stations
    30        being provided.  While you were there did you make
    31        observations of the usage of those stations?
    32        A.  You mean did I see anyone using them?
    33
    34   Q.   Is it something that you checked up on to see whether
    35        people were using them on a regular basis or not?
    36        A.  No.
    37
    38   Q.   In the same paragraph, what was the purpose of the birds
    39        being sprayed with water immediately prior to the stunning
    40        equipment?  Is that to do with hygiene?
    41        A.  No, that is to ensure there is a good electrical
    42        contact.
    43
    44   Q.   Did you ask how long they had been doing that, carrying out
    45        that practice?
    46        A.  Spraying the birds with water?
    47
    48   Q.   Yes.
    49        A.  No.
    50 
    51   Q.   You did not? 
    52        A.  No. 
    53
    54   Q.   The figures at the bottom of the page in the final
    55        paragraph:  "An estimated 1.5 per cent of birds arriving at
    56        the plant were rejected as unfit for human consumption for
    57        reasons of being dead on arrival, diseased or damaged
    58        during the processing."  Was that the figures that Sun
    59        Valley Poultry gave you?
    60        A.  Yes.

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