Day 069 - 19 Dec 94 - Page 18


     
     1
     2   Q.   How widely does Tysons distribute the chicken which it
     3        makes in Arkansas?
     4        A.  All over the United States.  They are the largest
     5        producers of chicken in the world.  Just to give you an
     6        idea, as big as we are, they only produce four per cent --
     7        about four per cent of what they can produce, we only
     8        consume four per cent of their products.
     9
    10   Q.   You only consume four per cent of Tysons products?
    11        A.  That is correct.
    12
    13   Q.   One notices, for example, that one of your products,
    14        Chicken McNuggets, got all the way from Nashville,
    15        Arkansas, to Adak, Alaska -- which is probably about as far
    16        you can go in the United States?
    17        A.  In the United States, yes.  Tysons also exports
    18        products to other countries.
    19
    20   Q.   Does it export, for example, to Canada?
    21        A.  Yes, they do.
    22
    23   Q.   If a McNuggett is going to make the journey from Arkansas
    24        to Alaska, how does it make the journey, in what sort of a
    25        container?
    26        A.  It is always frozen, and we do have specifications
    27        requiring the temperatures in which they are to be frozen.
    28
    29   Q.   Pause there to tell us to what temperature they are frozen?
    30        A.  OK.  At a target temperature of zero degrees; and we
    31        have recorders in every place throughout the distribution
    32        chains, from the time it leaves the plant in a truck; we
    33        have temperature monitoring devices that will record that
    34        temperature all the way to the place where it is received.
    35        There is a person that will inspect those records.  There
    36        is a person that will reject the product if the products
    37        were temperature abused; and even if it reaches our
    38        restaurants, we have a programme at store level which we
    39        inspect the products.  A product that is in any bad
    40        condition is rejected at any stage over the process from
    41        the time that the chick is born.
    42
    43   Q.   I was going to ask you about that.  Suppose this McNuggett
    44        (which it was) was in Alaska; would it travel all the way
    45        from Arkansas to Alaska by refrigerated truck?
    46        A.  In this case, it probably went by ship.
    47
    48   Q.   Suppose it went by ship, suppose it went by truck -- it
    49        does not matter -- if a truck load of McNuggetts, if
    50        something goes wrong with the refrigeration unit in a ship 
    51        or truck, as I suppose it can do ----- 
    52 
    53   MR. JUSTICE BELL:  It would have to go by both, would it not, by
    54        ship for part of the way, and it must have gone by truck to
    55        the port, and then by ship.
    56
    57   MR. RAMPTON:  That is correct.  This is not a case of alleged
    58        poisoning, this is a case of a metal ring, so for this
    59        purpose it is not a good example.  But suppose, on arrival
    60        at Anchorage in Alaska, or anywhere in the United States, a

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