Day 095 - 02 Mar 95 - Page 39
1 A. Yes, Tysons' data, it is the performance-based
2 inspection system. It is different from this one. What you
3 have here are some directives regarding corrective actions
4 while this is run with the product in movement. What we
5 saw in the morning were pre-operational checks. What we
6 saw yesterday, no product was run under those conditions.
7
8 Q. We will come to that in a minute. The point I am making is
9 that they are saying, are they not, they are not saying
10 that anything is not perfect will be classified as
11 something, as a deviation automatically?
12 A. Not necessarily, no.
13
14 Q. Let alone deficiency.
15
16 MR. JUSTICE BELL: Are you saying that this does not help us
17 with regard to the Tysons' printouts we saw yesterday?
18 A. That is correct, sir.
19
20 Q. This is something different?
21 A. Yes, it is.
22
23 MR. MORRIS: Well, we will see in a minute.
24 A. What he needs is the performance-based inspection
25 system directives.
26
27 Q. Well, this is what I asked for to explain that particular
28 form from that department.
29 A. I do not know -----
30
31 Q. It comes on to that later on.
32 A. I do not know the letter that you sent, but if you ask
33 for that, if need be, I can provide you with a copy of
34 that.
35
36 Q. Yes, if you want to, that is fine. It talks about, in that
37 point 2, something like a light bulb was missing or
38 something. It then says: "In both these instances above, a
39 small point, product wholesomeness is not in jeopardy.
40 Conditions such as these having no or very remote potential
41 for affective product wholesomeness should be identified on
42 the schedule as acceptable." In other words, if there are
43 trivial, what you might describe as trivial deficiencies --
44 not deficiencies -- as long as it does not affect the
45 product wholesomeness it will not be categorised?
46 A. It will be categorised. That is exactly what it says.
47 There will be a citation for minor, major or critical. For
48 example, if the light bulb went out and it is outside the
49 processing line, even if it is outside the plant, you will
50 be cited for that. That is what it is saying.
51
52 Q. It says that if one of several lights is burned out yet
53 there is sufficient light to perform inspections, then that
54 would still be acceptable?
55 A. That is correct.
56
57 Q. Then if we go over the page on page 4, point 4,
58 "Deficiencies may be classified as critical, major or
59 minor. Product, equipment, facilities, etc., involved in
60 critical deficiencies will require application of a US
