Day 021 - 29 Jul 94 - Page 38


     
     1   Q.   And?
              A.  Well, I am talking here about any kind of -----
     2
         MR. JUSTICE BELL:  All conceivable risks it is dealing with, is
     3        it?
              A.  It is, that is right, that might in any way be related
     4        to the food we eat.
 
     5   MR. MORRIS:  So, in terms of reducing risks, you are saying it
              would not be costly, that would be no problem then?
     6        A.  No, I did not say that.
 
     7   Q.   If we do not talk about all conceivable risks because I do
              not think anyone is talking about all conceivable risks,
     8        if we talk about reducing ill-health problems and diet,
              yes?
     9        A.  That is a separate issue.
 
    10   Q.   Is there cost considerations then for McDonald's, would
              you advise them?
    11        A.  Well, as a general statement, there is always a
              possibility that there would be costs considerations.  I
    12        do not think that is at issue.
 
    13   MR. JUSTICE BELL:  What I think Mr. Morris is getting at is in
              your first point you talk about avoiding all conceivable
    14        risks ---
              A.  Yes.
    15
         Q.   -- but that all conceivable risks are not relevant, do not
    16        appear in the second point, nor do they appear in the
              third point, so you seem to be saying in that sentence,
    17         "Third", could be treated as saying that there may be
              some compromise on safety aspects because of cost; is that
    18        what are you saying or not?
              A.  Yes, as a general statement, yes.
    19
         MR. MORRIS:  Yes, but I mean -----
    20        A.  If I can just give an example?  It is probably easier
              to do it in relation to the presence of pathogenic
    21        bacteria.  Clearly, there could be -- I mean, the level of
              specification and the number of checks that have to be
    22        carried out in a plant and during the course of the
              operation are going to have an effect on the total cost.
    23
         Q.   Leave that aside.  How does this third point relate, if at
    24        all, to McDonald's food?  I mean, if it is just a general
              statement, there we are, but Mr. Morris may be thinking it
    25        relates to McDonald's?
              A.  It is a general statement dealing with the issues 
    26        specifically of trying to achieve absolute safety. 
  
    27   MR. MORRIS:  So, setting aside absolute safety, which you would
              probably agree is completely unobtainable.
    28
         MR. JUSTICE BELL:  That is what you say.
    29        A.  Yes.
 
    30   MR. MORRIS:  It is an absolute?
              A.  Yes.

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