Day 068 - 16 Dec 94 - Page 37
1 use frozen raw material; is that, as you understand it, a
2 specification?
3 A. OK. Not necessarily. This specification is also, even
4 though on the top it says "US frozen meat patty", it
5 describes the type of patty, that is our name. It does not
6 imply that it is only for the US. We use the specification
7 globally to assure consistency and to have the same
8 product. If we modify that, there are specification
9 addendums (sic) that I believe are included.
10
11 Q. International?
12 A. International.
13
14 Q. Which say that you can use frozen. I saw that.
15 A. It does say in the international specifications that we
16 can use frozen.
17
18 Q. You can?
19 A. Yes, if you look -----
20
21 Q. But in the US itself, is that a specification then that is
22 compulsory on the suppliers?
23 A. It is, if you look specifically, not for all the raw
24 materials on top; and if I might describe so that you can
25 have a better idea, it says "minimum 50 per cent lean,
26 boneless meat". It is a specific type of meat. It is,
27 when we say "fresh only, not frozen" it is directly related
28 to that specific 50 per cent lean meat, boneless meat.
29
30 MR. MORRIS: Is there other meat that is used?
31
32 MR. JUSTICE BELL: Look at the page before.
33
34 MR. MORRIS: So the meat that is 75 per cent and 95 per cent
35 lean, boneless beef does not have a specification that it
36 must be frozen; yes?
37 A. I am sorry. Which one?
38
39 MR. JUSTICE BELL: Page 19.
40 A. The 75 to 95 per cent, right?
41
42 MR. MORRIS: Yes.
43 A. That is correct.
44
45 Q. So ----
46 A. Just to clarify my answer, your question was that the
47 75 per cent to 95 per cent lean, boneless meat is not to be
48 used in a frozen stage, right, is that correct? Is that
49 what you asked me?
50
51 Q. It should not be frozen when it arrives. What I am trying
52 to establish -- it is not a trick -- is whether you are
53 saying that you have never seen any frozen beef, raw
54 material, in any of your process plants?
55 A. That is correct.
56
57 MR. MORRIS: You do not know what happens in the other
58 20 per cent?
59
60 MR. JUSTICE BELL: He says he has not seen the other
