Day 070 - 20 Dec 94 - Page 30
1 employees' equivalent of that, I do find uninviting. So,
2 what I am still searching for is some little row which
3 gives a modicum of information apart from just a total
4 figure for the year, but avoids having to have discovery of
5 large numbers of that kind of document.
6
7 MR. MORRIS: I would expect the Plaintiffs to have computer
8 printouts of accident statistics on a regular basis.
9
10 MR. JUSTICE BELL: Let us see what is produced upon further
11 enquiry.
12
13 MS. STEEL: Dr. Gomez Gonzalez, a number of times in his
14 evidence, referred to carrying out audits on suppliers and
15 suppliers doing audits of slaughterhouses, which he said he
16 would be entitled to look at and get copies of. We would
17 submit that the Plaintiffs should have to disclose copies
18 of these audits for 1989 or 1990 or, if those years are not
19 available, then the nearest available year to those years.
20
21 He also referred to extra pages of specifications in terms
22 of animal welfare in relation to the meat product
23 specifications.
24
25 MR. JUSTICE BELL: Were the audits the ones where we had a table
26 of shortfalls with a percentage at the end? They were
27 inspections, some scheduled and some unscheduled. That was
28 a different topic, was it not?
29
30 MR. RAMPTON: My Lord, that is different. That is by the FSIS,
31 I think. What we have is an English version (a sample
32 only) of a McKey audit form. That has already been
33 disclosed. We will ask the Americans whether they have
34 anything similar in their possession and, if so, to produce
35 it.
36
37 There is in the documents that Dr. Gomez Gonzalez was able
38 to obtain while he was still here -- I do not know whether
39 it is called an audit form or not, I think it is very
40 likely is -- for example, a Tyson broiler supervisor
41 report, which is more or less devoted entirely to the
42 welfare of the chickens. It is a detailed document. It
43 may be the sort of thing that Dr. Gomez Gonzalez was
44 talking about.
45
46 MS. STEEL: I think in this country and in the USA the
47 Plaintiffs' witnesses have referred to audits or
48 inspections being carried out. They are relying on them to
49 claim that they are concerned about the welfare of
50 animals. I think we are entitled to see what those forms
51 in actual fact show in terms of what the results were, not
52 just what the questions asked were.
53
54 MR. JUSTICE BELL: Have you any idea of what volumes are
55 involved?
56
57 MS. STEEL: In this country, I think Mr. Rampton said there
58 were, was it, about eight slaughterhouses supplying them,
59 or something like that -- six; then there would be
60 Sun Valley as well. Then, I think, in America -- yes,
