Day 102 - 13 Mar 95 - Page 43


     
     1        A.  We do not -----
     2
     3   Q.   What percentage of birds are affected?
     4        A.  We do not actually know.  We monitor dead-on-arrivals
     5        as a whole, and we do not specifically look at every
     6        dead-on-arrival to see the cause of death.  So, I cannot
     7        answer -- I do not know the answer to the question.
     8
     9   Q.   So, for all you know, there could be birds with crushed
    10        heads in every load?
    11        A.  Except that we do not -- we do investigate cases where
    12        we have increased numbers of dead-on-arrival.  We obviously
    13        carry out postmortems on those and it is not an injury that
    14        I find commonly.
    15
    16   Q.   It is an injury that occurs more frequently than at other
    17        plants, is it not?
    18        A.  According to that piece of research.
    19
    20   Q.   You would accept that research, would you?
    21        A.  Well, the research was done two or three years ago with
    22        our full collaboration, and I think it was a way which
    23        highlighted something which was happening which we were not
    24        totally aware of.  I think as a result of that piece of
    25        research it has helped us to improve our practices and
    26        procedures.
    27
    28   MR. JUSTICE BELL:  Is that the February 1993 report of
    29        Dr. Gregory or another one entirely?
    30        A.  It is Gregory's research.  I am not sure of the date.
    31
    32   MR. MORRIS:  1992, in his statement, Gregory and Austen.
    33
    34   MS. STEEL:  Yes, November 28th, 1992.
    35
    36   MR. MORRIS:  It was in Mr. Gregory's statement, plant F at Sun
    37        Valley.
    38
    39   MS. STEEL (To the witness):  There was a recommendation in that
    40        paper, was there not, that the design of the front upper
    41        lip of the drawers could be improved so that if a bird's
    42        head or neck did get trapped it would not be injured.  Has
    43        Sun Valley implemented that suggestion?
    44        A.  No, because we felt it was easier just to tell people
    45        to be careful not to trap the heads, rather than to have to
    46        redesign all the drawers.
    47
    48   Q.   So you gave the workers extra time to take more care, did
    49        you?
    50        A.  They have always had time to take care. 
    51 
    52   Q.   It would be simple to change the design of the drawers, 
    53        would it not?
    54        A.  But we did not feel that that suggestion was a
    55        particularly practical one.
    56
    57   Q.   Practical?  Why was it not practical?
    58        A.  From a design point of view.
    59
    60   Q.   Why not?

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