Day 105 - 16 Mar 95 - Page 30


     
     1
     2   Q.   So are you saying that these swab tests, they seem to be
     3        monthly, is that your understanding?
     4        A.  Yes, that is my understanding of it.
     5
     6   Q.   They are done monthly?
     7        A.  Yes.
     8
     9   MR. JUSTICE BELL:  Could you just pause a moment?  Yes?
    10
    11   MR. MORRIS:  Are you saying that the grading system used for the
    12        monthly swab tests, all the grades that they choose to give
    13        a range of, they have not -----
    14
    15   MR. JUSTICE BELL:  What you are saying is that none of the
    16        grades denote to you a risk?
    17        A.  Indeed.
    18
    19   Q.   And you are not just working on the grades, you are
    20        actually looking at the counts which are there?
    21        A.  Yes.
    22
    23   Q.   That contamination, cross-contamination, increases in
    24        counts, and counts at the end of the day are all relative,
    25        and you cannot infer any lack of safety from a fact of
    26        contamination, from a fact of cross-contamination, from a
    27        fact of increasing count.  What you have to do is look at
    28        the counts to see whether there is a risk and, if so, how
    29        great it is.  Is that, in summary, your position?
    30        A.  Yes.
    31
    32   MS. STEEL:  What would be the difference in action taken by the
    33        company depending on the different grade?
    34        A.  Within the band of grades we are discussing, which are
    35        not into the territory of public health risk, the only
    36        grade which is frequent and recurring which will call
    37        attention to itself at all would be the "E" grade, because
    38        it does give an indication that it is a situation to keep
    39        an eye on.  The action taken would be, as I have said, to
    40        bring this matter to the attention of the people
    41        responsible.
    42
    43   Q.   And to seek some kind of improvement?
    44        A.  I would say, rather, to make sure that it does not go
    45        beyond that point, because objectively looking at the
    46        count, and the ones we have before us, which, obviously,
    47        have not been selected to present a particularly good or
    48        bad picture either way.  There is only one count, the
    49        actual measurement itself, there is only one of them that I
    50        have referred to which even comes into the mid range of a 
    51        customer specification.  In other words, half a million 
    52        organisms per gramme on meat.  That is still acceptable, 
    53        but that is way, way above any of the other counts that are
    54        shown within the grades.
    55
    56        I can only repeat that the grades are all within -- they
    57        are not assessing the suitability of the meat or the safety
    58        of it; they are merely giving an indication of the
    59        efficiency of, on the one hand, the cleaning programmes,
    60        which have not been called into question, so far as I know,

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