Day 069 - 19 Dec 94 - Page 23


     
     1
     2   Q.   To be fair, we should not be preparing any food in this
     3        courtroom.  But can you compare for us the conditions, the
     4        hygiene conditions, of a plant like this one, Tysons plant
     5        at Nashville, Arkansas, with the conditions to be found in
     6        an ordinary domestic kitchen where the housewife is house
     7        proud?
     8        A.  They are several times better than any kitchen in the
     9        house.  They are better than many hospitals that I have
    10        seen.  If I might add, even if the inspector finds a
    11        deficiency -- and he inspects the plant before operations
    12         -- so even if he finds a deficiency, that deficiency is
    13        taken care of before the start of the plant.  The inspector
    14        will not allow the production of any food if he feels the
    15        deficiencies are not taken care of.  He also has the
    16        ability, he is empowered, and the authority, to stop the
    17        line if he feels there are any deficiencies.
    18
    19        In this particular case, the objective also is to build a
    20        history of the plant, and those plants who have shown a
    21        higher degree of deficiencies are placed on an intensified
    22        inspection, so that they are more focused towards the plant
    23        that have more deficiencies and less to the plants who do
    24        not have deficiencies.
    25
    26   Q.   Tell us about Tyson's plant at Nashville Arkansas; what is
    27        its sanitary history?
    28        A.  Perfect.  They have never ever been placed on
    29        intensified inspection.
    30
    31   Q.   If they were placed on intensified inspection, would
    32        McDonald's know about it?
    33        A.  Absolutely.
    34
    35   Q.   What would McDonald's reaction be?
    36        A.  It will be not to use -- well, the US DA would not
    37        allow us to use any products, coming from any plant, that
    38        is not fit for human consumption, that is not wholesome.
    39        The objective of the FSIS is to ensure that products are
    40        wholesome.  So we obviously will not use any of the
    41        products if they are not produced in a hygienic manner.
    42
    43   Q.   How often is a plant like this Tyson plant at Nashville
    44        cleaned during the course of a day or week or a month?
    45        A.  It would depend on the area of the plant.  At night, it
    46        will follow a thorough clean up from wall to wall, from
    47        floor to ceiling, at least once over the night, and it is
    48        cleaned routinely throughout the day.
    49
    50   Q.   Continuously throughout the day? 
    51        A.  That is correct. 
    52 
    53   Q.    Do that have special staff to clean it?
    54        A.  That is correct; and equipment, I might add.
    55
    56   Q.   And equipment?
    57        A.  Equipment, yes.
    58
    59   Q.   Do the inspectors inspect the cleaning equipment?
    60        A.  Absolutely.  They inspect everything in the facilities,

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