Day 103 - 14 Mar 95 - Page 31
1
2 MR. RAMPTON: My Lord, I do not think it says four degrees;
3 I think it says minus four degrees, actually.
4
5 THE WITNESS: That is correct.
6
7 MR. MORRIS: Is that true?
8 A. It says minus four degrees on there.
9
10 Q. OK. We will leave that then. You say there are something
11 like 30 to 40 microbiological tests a day of McDonald's
12 chicken products, raw materials. Do you know how many
13 tests are done for other -- is it roughly the same for all
14 other tests, it is about the same number of tests?
15 A. What other tests?
16
17 Q. I do not know. I mean, for example, the cartilage
18 tests ---
19 A. Yes.
20
21 Q. -- which would be done?
22 A. Yes, I could not be certain of the actual numbers.
23
24 Q. Is it something roughly equivalent?
25 A. Well, I think you get, by looking at these documents,
26 you get a feel for the number of tests that we do in a
27 day. Some of them are tests, some of them are
28 measurements, some of them are quality control checks.
29
30 Q. Can we just go to the fax number at the top, page 10? It
31 is ESSAI OIS, No. 6?
32 A. Yes.
33
34 Q. Can you see that?
35 A. Yes.
36
37 Q. Do you know what this is about?
38
39 MR. JUSTICE BELL: You said right at the beginning of your
40 evidence that about one-fifth of the Sun Valley turnover
41 was McDonald's. Is that why 20 per cent of the tests are
42 on McDonald's, purely and simply, it is one-fifth of the
43 product?
44 A. No, it is not really because some other products would
45 actually have more testing relatively. For example, if we
46 are producing cooked products which are actually ready to
47 eat, proportionately we would do more tests on those.
48
49 Q. But does the number of tests, i.e. the 20 per cent, take
50 into account the fact that only 20 per cent of your produce
51 is for McDonald's anyway, or is it partly that and partly
52 the fact that it is not a finished product, or entirely one
53 or the other?
54 A. I mean, the actual microbiological tests on food for
55 McDonald's are probably less in proportion because it is a
56 raw product that we are supplying, but the number of tests
57 around it, for example, weighing, temperature tests,
58 measurements along the line are probably proportionately
59 more because it is actually quite a complex process.
60
