Day 085 - 08 Feb 95 - Page 43
1 MR. JUSTICE BELL: Point me to the bit of his statement where he
2 says that.
3
4 MR. MORRIS: I am sorry, yes.
5
6 MR. JUSTICE BELL: It is always helpful. For instance -- it has
7 occurred to me -- while you are going through someone's
8 statement, if you always give the page and the paragraph,
9 one can find it immediately, otherwise one is scouring over
10 pages one probably never need look at.
11
12 MR. MORRIS: It is Mr. Clark's statement, page 11. There is the
13 large paragraph in the centre and it is the second sentence
14 after that. It says: "However to be absolutely above
15 reproach", it says, "a review of the time/temperature
16 conditions would be advisable." Obviously, that is only
17 one abstracted part.
18
19 MR. JUSTICE BELL: What I want to know is, have you got a case
20 to put to this witness or any other witness who deals with
21 it that, for instance -- this, in fact, is old equipment so
22 it is not the best example anyway, if one is comparing with
23 what Mr. Clark is reporting -- have you got a suggestion
24 that it should be reading instead of 325, 340, 330, 345 or
25 something like that?
26
27 MR. MORRIS: It seems from various documents, including
28 Mr. Clark's chart on page 14, that the recommended
29 temperature limit for the lower grill in the clamshell -- I
30 do not know if that is exactly the same as that calibration
31 check list -- should be 350; whereas the document we have
32 just looked at says that there are, if you like, blind
33 spots or whatever at certain parts of the grill that would
34 be as low as 325. So, we are trying to identify where
35 there are weak areas or room for improvement, and that
36 could be the cause of food poisoning incidents.
37
38 MR. JUSTICE BELL: That is not even this equipment. That is a
39 clamshell grill with a top plate and a lower grill, is it
40 not? I am going to invite you to carry on with your
41 cross-examination in a moment, but the sort of point I have
42 in mind, the moment it becomes apparent that this is old
43 equipment, gas fired, as I understand it, it clearly does
44 not relate to any equipment to which page 14 refers, does
45 it? It may relate to something else which is why I am
46 inviting you to refer to it.
47
48 MS. STEEL: I think this is the type of equipment that was in
49 use at Preston when they had the outbreak there.
50
51 MR. JUSTICE BELL: Yes, then if you have a figure to put, this
52 is what I want to know, for instance: Let us suppose you
53 might ask if he knows this was the equipment at Preston
54 Friargate, Mr. Atherton might not know at all. If you have
55 a suggestion to make, for instance, that there would not
56 have been any outbreak of food poisoning at Preston if the
57 plates had been a minimum of 340 rather than 325, that is
58 what I need put, or are we just on a search for an
59 explanation of what appendix 2 means, because the moment
60 you find it is about a gas fired thing, unless you have a
