Day 093 - 28 Feb 95 - Page 71


     
     1
     2   MR. JUSTICE BELL:  You can non-conform with the speed limit in
     3        the middle of London by driving at 31 miles an hour.  It
     4        does not necessarily help you as to whether it is very
     5        important.  You may have a good point but at the moment
     6        I am sadly lacking in information as to just what it
     7        covers.
     8
     9        I do not know whether Dr. Gomez Gonzalez can help us or not
    10        on it.  I appreciate the difficulty you have if there is
    11        no-one from Tysons or no-one from US DA giving evidence and
    12        if you may not have a witness of your own who can help us,
    13        but we are -- there is a fair bit of blind man's buff at
    14        the moment, it seems to me.
    15
    16   MR. MORRIS:  I would have thought the witness would have known
    17        about these matters having left the US DA in the -----
    18
    19   MR. JUSTICE BELL:  Ask him if he does, you see, if he knows
    20        what --   (To the witness):  Can you give an example under
    21        equipment disassembly of the sort of noncompliance which
    22        might score under E, the minor column, or F, the major
    23        column, or G, the critical column, do you know?
    24        A.  I do not know the specifics of each one.  I do know how
    25        this is used.  The entire forms, the last column, that
    26        means statistical process level.  It gives an indication
    27        for the US DA to have an indication of the entire plant,
    28        give it a number.  With that number, the higher the number
    29        the more problems that plant has.  It goes into a central
    30        computer for the United States Department of Agriculture
    31        and they have an idea how the plants are doing.
    32
    33   Q.   Yes, I can see that.  Just pause a moment.  Let us have a
    34        look.  I mean, if you turn to page 57, for instance, under
    35        "storage" it has "prevention of contamination"?
    36        A.  Yes, I see it.
    37
    38   Q.   Do you see that?
    39        A.  Yes, I do.
    40
    41   Q.   Can you, for example, tell me what amount might amount to
    42        minor noncompliance under the heading of "preventing of
    43        contamination" or what might amount to a major one or what
    44        might amount to a critical one?
    45        A.  Yes, I can.  For instance, if there is some
    46        condensation on the ceiling that is away from any producing
    47        areas, that will be a minor.  If it is the same
    48        condensation of water, it could be just a few drops, that
    49        is close to a processing line -----
    50 
    51   Q.   Yes, we are in storage now, you see. 
    52        A.  It is the same if it is in storage. 
    53
    54   Q.   Sorry?
    55        A.  Instead of a processing area would be a container with
    56        meat.
    57
    58   Q.   Right, I see.
    59        A.  If they forgot to close the, for instance, there is a
    60        container of meat that is covered with plastic, and they

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