Day 103 - 14 Mar 95 - Page 28
1 be -----
2
3 MR. JUSTICE BELL: Might it be a lesser month or should it keep
4 at the same pressure?
5 A. Yes, it would be. I think they did shut down for a
6 short time, I think, may be a week or so, but certainly not
7 the whole month like most French factories.
8
9 MR. MORRIS: So, how many bins do you send to France in a day?
10 A. I cannot answer. I just do not know.
11
12 Q. You do not know?
13 A. I have no idea.
14
15 Q. Do you have any idea what the weight of a bin is?
16 A. 500 kilos, I said before.
17
18 Q. 500 kilos. Do you know how many kilos you produce a day
19 from Sun Valley for McDonald's use?
20 A. No, I do not.
21
22 Q. Approximately?
23 A. I do not have any idea, I am afraid. It is not a
24 figure I would deal with normally.
25
26 Q. How many samples do you take from a bin when it is sampled,
27 or do they take from a bin? They just take a sample from a
28 bin to check, do they?
29 A. For bacteriological tests?
30
31 Q. Yes, at Orleon.
32 A. The normal practice is to take five samples and then
33 aggregate them.
34
35 Q. Do you happen to know if the highest -- well, the highest
36 found would be not for the highest in any one sampling; it
37 would be the highest found as an aggregate of five samples?
38 A. Yes.
39
40 Q. So, in fact, some of samples might have been higher than
41 that figure -- well, they would have been higher than that
42 figure. That is the average figure, yes? The high figure
43 there is the average for the highest scoring bin?
44 A. Yes, normal bacteriological practice is to take several
45 samples and aggregate them because of the inherent
46 variability of a natural product.
47
48 Q. Exactly, yes. So, when you have a bin, for example, GR
49 skin in the laboratory analysis chart, where the highest
50 was 1.3 million bacteria per gramme, it is quite possible
51 that some of that meat might have been over 5,000,000 per
52 gramme, is it not?
53 A. I think I have explained it before, that raw material
54 is an inherently variable product. So, to get a more
55 accurate result you take five samples and aggregate them.
56
57 Q. Of course, because of the large volume which you put
58 together in this kind of system, then it is inevitable that
59 you are only going to find what the position is like in a
60 very small part of ---
