Day 093 - 28 Feb 95 - Page 70


     
     1   Q.   So they would have stopped the entire plant,
     2        presumably  ---
     3        A.  Yes.
     4
     5   Q.   -- at that stage?
     6        A.  Yes.
     7
     8   Q.   On that day?
     9        A.  That is correct.
    10
    11   Q.   How many times do you know of the entire plant being closed
    12        down by the US DA, the Tysons Arkansas plant?
    13        A.  None.
    14
    15   Q.   Does not Tysons inform you about hygiene problems with its
    16        plant?
    17        A.  Yes, it does.
    18
    19   Q.   But they do not tell you about such severe problems that
    20        would result in the plant being closed down?
    21        A.  If they close the plant, we obviously would know.
    22
    23   Q.   So in this case, in June 1993, you were not informed or, as
    24        far as you know, the plant did not close down?
    25        A.  The plant has not been closed down at any time up to
    26        1992.
    27
    28   Q.   Even though 95 per cent of the tests on equipment
    29        disassembly proved to be not conforming to -----
    30        A.  No, you are getting it wrong.  That is not what I mean.
    31
    32   MR. RAMPTON:  My Lord, I have difficulty about this.  Mr. Morris
    33        keeps making assertions about the true interpretation of
    34        the meaning of this document.  As far I am aware, he is no
    35        evidence at of what it actually ----
    36
    37   MR. MORRIS:  I am relying on the witness's definition which was
    38        non-conformity.
    39
    40   MR. JUSTICE BELL:  Yes, but we do not know non-conformity with
    41        what.
    42
    43   MR. MORRIS:  I just said "non-conformity".
    44
    45   MR. JUSTICE BELL:  But that may not get you very far or it may
    46        get you far, it may not -- I can see the figures for
    47        myself.
    48
    49   MR. MORRIS:  Yes.
    50 
    51   MR. JUSTICE BELL:  What I do not know is what kind of feature 
    52        the inspector has to see on equipment disassembly to say 
    53        there is a minor noncompliance there, or a major
    54        noncompliance there, or a critical noncompliance there.
    55        I just do not know what they are.  It appears that the
    56        witness does not know what they are either.
    57
    58   MR. MORRIS:  I am relying on the witness's definition of the
    59        bringing in the actual scoring would be non-conformity.
    60        Whether it is minor, major or critical -----

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