Day 094 - 01 Mar 95 - Page 52


     
     1        A.  No, I have not.  The speed of the line has no effect on
     2        this issue.
     3
     4   Q.   What would happen then if there were faeces on the table?
     5        A.  On what table?  I am sorry.
     6
     7   Q.   You said you had seen faeces on the table.
     8        A.  Yes, when -- the stomach, entire stomach, is dropped
     9        into a stainless table, then is removed the offal and goes
    10        through a totally separate process.  There is always hot
    11        water running through that table that is constantly killing
    12        all the bacteria and sanitizing the table.
    13
    14   Q.   But meat also goes over that table?
    15        A.  The meat goes, it is a thoroughly different and
    16        separate pathway, a thoroughly different process.
    17
    18   Q.   Were you aware of Montfort being slapped with notices of
    19        197 violations of safety rules by the Federal Occupational
    20        Safety and Health Administration?
    21        A.  No, I was not.
    22
    23   Q.   Would it concern you -----
    24
    25   MR. RAMPTON:  My Lord, I am sorry.  This has to do with employee
    26        safety, as far as I can see.  McDonald's could not
    27        conceivably be thought to have any responsibility for the
    28        safety of employees in either their immediate or their
    29        distant suppliers.
    30
    31   MS. STEEL:  It has a relevance because if things are going so
    32        fast that workers are getting injuries, it may affect the
    33        hygiene as well.
    34
    35   MR. RAMPTON:  Then that is the question to ask, not whether he
    36        is aware of environmental ------
    37
    38   MS. STEEL:  I was starting to ask by asking whether he was aware
    39        of it.
    40
    41   MR. JUSTICE BELL (To the witness):  In any event, do you know
    42        anything about notices of violation of Federal Safety Rules
    43        being served on Montfort?
    44        A.  Was I aware of them?  No.
    45
    46   MS. STEEL:   Would it concern you if that was correct?
    47        A.  In what sense?
    48
    49   Q.   Would it concern you that the company your meat was coming
    50        from seemed to have these ----- 
    51 
    52   MR. JUSTICE BELL:  Put it this way:  Would you be concerned if 
    53        the pressure of the work was such that there was a high
    54        rates of injuries and strains to the workers, the thrust of
    55        it being that if they are working under such stress that
    56        there are going to be slips so far as hygiene is concerned?
    57        A.  Would I be concerned?  Yes.
    58
    59   MS. STEEL:   Is that something that the company looks into in
    60        respect of where its meat comes from?  Does it look into a

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