Day 102 - 13 Mar 95 - Page 43
1 A. We do not -----
2
3 Q. What percentage of birds are affected?
4 A. We do not actually know. We monitor dead-on-arrivals
5 as a whole, and we do not specifically look at every
6 dead-on-arrival to see the cause of death. So, I cannot
7 answer -- I do not know the answer to the question.
8
9 Q. So, for all you know, there could be birds with crushed
10 heads in every load?
11 A. Except that we do not -- we do investigate cases where
12 we have increased numbers of dead-on-arrival. We obviously
13 carry out postmortems on those and it is not an injury that
14 I find commonly.
15
16 Q. It is an injury that occurs more frequently than at other
17 plants, is it not?
18 A. According to that piece of research.
19
20 Q. You would accept that research, would you?
21 A. Well, the research was done two or three years ago with
22 our full collaboration, and I think it was a way which
23 highlighted something which was happening which we were not
24 totally aware of. I think as a result of that piece of
25 research it has helped us to improve our practices and
26 procedures.
27
28 MR. JUSTICE BELL: Is that the February 1993 report of
29 Dr. Gregory or another one entirely?
30 A. It is Gregory's research. I am not sure of the date.
31
32 MR. MORRIS: 1992, in his statement, Gregory and Austen.
33
34 MS. STEEL: Yes, November 28th, 1992.
35
36 MR. MORRIS: It was in Mr. Gregory's statement, plant F at Sun
37 Valley.
38
39 MS. STEEL (To the witness): There was a recommendation in that
40 paper, was there not, that the design of the front upper
41 lip of the drawers could be improved so that if a bird's
42 head or neck did get trapped it would not be injured. Has
43 Sun Valley implemented that suggestion?
44 A. No, because we felt it was easier just to tell people
45 to be careful not to trap the heads, rather than to have to
46 redesign all the drawers.
47
48 Q. So you gave the workers extra time to take more care, did
49 you?
50 A. They have always had time to take care.
51
52 Q. It would be simple to change the design of the drawers,
53 would it not?
54 A. But we did not feel that that suggestion was a
55 particularly practical one.
56
57 Q. Practical? Why was it not practical?
58 A. From a design point of view.
59
60 Q. Why not?
