1. I am employed by McDonald's Restaurants Ltd as Quality Assurance Supervisor. I am 29 years of age. I joined McDonald's in April 1989 having previously worked for Arthur Branwell, an ingredients supplier to the food and drinks industry, for 2 years in the quality control department. I have a BSc. (Hons) in Food Science from Kings College London.
2. I have read the London Greenpeace leaflet which is the subject of this litigation and am familiar with its contents.
The Role of the Quality Assurance Department
3. The Quality Assurance Department has a vital role in the company's efforts to ensure the quality and safety of our food products. It is we who work extremely closely with those who manufacturer and supply the food products which we sell and those who distribute them to ensure that at all stages of the production and distribution process the highest possible standard. of cleanliness and food safety are achieved.
The monitorinq of suppliers
4. Within the food industry in the United Kingdom, most quality food retailers now regularly monitor the quality and safety standards of their immediate suppliers. They will not always go further and monitor the suppliers of those suppliers or others further down the food and distribution chain. They will instead rely on their suppliers to monitor those who in their turn supply to them. I hope that what follows in this statement will demonstrate that in many cases we go further than that.
5. Any food supplier who wishes to do business with McDonald's must subject themselves to very strict requirements. They must allow us to visit them a minimum of twice a year, and in fact major suppliers are more than likely to be visited every fortnight. These visits can include "surprise" visits.
6. Every supplier must agree to follow an adequate quality assurance programme, approved by ourselves to ensure that the products supplied meet our rigorous specification. They must keep detailed documentary records of the manufacturing and quality tests required by our Department. These will include where applicable micro-biological tests to determine the level of microbial activity in a product, which must be within carefully defined limits. On the announced or unannounced inspections a supplier must allow our representatives to review quality assurance procedures during the manufacture of the product and to assess hygiene standards and to review all the quality records related to our products which we require them to keep. They must be filed in a confidential file and must be retained for a minimum of three years.
7. In addition, the supplier must maintain a "black book" and have it available for inspection. This black book must contain such details as raw material specifications and the results of the tests performed on those materials to ensure compliance with specification, traceability, manufacturing equipment, processing procedures, formula, in-process testing, an HACCP Plan (or some other recognised method of quality assurance control), quality control testing, equipment maintenance, and cleaning and planned sanitation procedures (including pest control programmes).
8. We insist that, where necessary, food products are inspected and passed by a metal detector system approved by ourselves.
9. Major suppliers must send to us summary sheets of their own quality control results which are received and double checked by ourselves.
10. Samples are drawn at random for laboratory analysis to independently check the suppliers results. In addition, major suppliers are regularly required to submit samples to the McDonald's laboratory in Frankfurt to test for compliance with specification and taste testing.
11. I set out below some specific examples of the precautions we take in relation to major products.
12. We also insist that each supplier has the proven capability to track the distribution of all its products within 3 hours and they must have a written plan to describe how this will be accomplished. In the event that it is necessary to recall or recover stock in the food chain suppliers must immediately co-operate when directed by McDonald's in accordance with McDonald's own specified procedures. The supplier must notify McDonald's when they learn of a potential stock recovery of their product and must provide McDonald's with 24 hour telephone numbers for themselves.
13. Without exception, every beef product sold in a McDonald's Restaurant in the UK originates from McKey Foods Ltd. They have two plants at Scunthorpe and Milton Keynes. McKey employ highly qualified scientists to conduct detailed microbiological sampling of products supplied to them. Attached as Appendix 1 is a summary supplied to us by McKey of the Quality Control Checks carried out by McKey staff at their plants during the production of McDonald's hamburger patties. I can confirm that from my own knowledge, based on the many visits paid by members of the Quality Assurance Department, including myself, to the McKey plants, that this is an accurate summary. It is, I believe, largely self-explanatory. Of particular note, perhaps, are the points numbered 6; 7; 8; 13; 33; 34; 35; and 40. Points numbered 30 and 31 reflect the fact that McKey cook samples of the product on equipment identical to that used in McDonald's Restaurants as part of their quality control checks.
14. McKey work to microbiological guidelines agreed with McDonald's. Attached as Appendix 2 is a summary produced by McKey, which is to the best of my knowledge correct, which summarises those guidelines. As this note records, these guidelines are at least as stringent as those generally in use in the meat industry.
15. The McKey plants process deboned meat. They purchase that meat from approved abattoirs. McKey have systems for visiting their suppliers on announced and unannounced visits. The guidelines required by McKey are stringent, both in terms of the microbiological content of the product and of arrangements made for the hygiene of abattoirs. Attached as Appendix 3 is an example of the meat supplier audit form which is used by McKey on their visits to suppliers. This document is, I believe, self-explanatory and is extremely comprehensive. Our department also accompanies McKey on some of these visits to abattoirs so that we can see for ourselves that the standards of hygiene are kept high.
16. Summary reports are produced by McKey and, since 1991, sent to us on a weekly basis. An example of the quality control summary sheets ("QC Sheets") is attached to this statement as appendix 4. I believe the headings on this form are self-explanatory - note that the results of microbiological sampling are recorded. McKey themselves keep voluminous records of which the QC sheets sent to us are a summary.
17. In addition, in common with other major products, we do a further check by conducting a monthly store audit which is performed by the Quality Assurance Department on a randomly selected store. This includes physical and analytical checks on all raw food products at that particular restaurant.
18. As at the date of this statement we buy chicken from various suppliers. This is a short term measure because our major supplier, Sun Valley Ltd. have suffered a major fire at their factory in Hereford.
19. We monitor Sun Valley's standards in a similar way to that described in relation to McKey Foods Ltd above. They also receive regular visits, announced and unannounced, and are required to supply regular QC Summary Sheets. An example of the QC Summary Sheets which they submit is attached to this statement as appendix 5. It should be noted that included on these QC summary Sheets are details of their microbiological tests.
20. QC Summary Sheets cover both for the processed chicken products and for the meat prior to processing.
21. Attached as appendix 6 is a summary produced by Sun Valley Poultry Limited of the microbiological standards which we require for products which are supplied to us. This summarises the microbiological specification for UK chicken products which applies as at today's date. These differ from those which were used in 1989 only in the sense that the maximum permissible level of TVC was 5.0 x 106 at that time.
22. There is no legislative standard to which this specification can be compared. Sun Valley's standards are based on the guidelines of the ICMSF (International Commission of Microbiological Specifications for Foods) produced by the International Union of Microbiological Societies. Attached as appendix 7 is a photocopy of an extract from that body's 1986 publication entitled "Sampling for Microbiological Analysis" in which table 19 shows the recommended maximum TVC in chilled or frozen carcass meat as 1 x 107. In other words, the recommended maximum was half a log cycle higher than the standard to which Sun Valley were working 1989 and a whole log cycle higher than current practice. Generally speaking, the specification used in our products is, I believe, at least as strict as other operating specifications approved by other customers in the retail and catering sector. That is the view of Sun Valley and I agree with it.
23. Sun Valley grow birds specifically for our products, either in their own chicken houses or those of carefully selected contractors. All birds are reared from Sun Valley's own parent stock. Their contracted chicken houses are regularly inspected by Sun Valley.
24. The birds are fed on chicken feed produced in Sun Valley's own mill - even those birds reared by outside contractors are fed exclusively on Sun Valley's own feed.
25. Slaughtering and deboning a chicken is done by Sun Valley who also process the products. We regularly inspect all production facilities, together with hatcheries, chicken houses, and the feed mill.
26. Because Sun Valley grow the product which they then process, we can track the product very closely. In fact, with the coding system in use we can trace back each Chicken McNugget sold in a restaurant back to the actual chicken house it came from.
27. The pork products used for McDonald's McRib and the Breakfast Sausage are Supplied exclusively from McKey's. The details of all the quality assurance checks described above in relation to beef apply equally to pork. I attach as appendix 8 a copy of a sample QC summary sheet for pork.
Other McKey products
28. McKey also supply us with bacon for breakfast, spicy beef for pizzas, and ham and turkey strips used in salads. These products differ slightly from pork and beef since McKey buy them from the suppliers in pre-made form and further process them. The work done by McKey is subject to the same system of visits and quality control checks as described above, and McKey visit their own suppliers. In the case of these products, we do not ourselves visit those suppliers.
The monitoring of hygiene standards In the distribution process.
29. All deliveries to McDonald's restaurants are made by Golden West Foods Ltd. All suppliers make deliveries to their distribution centres at Heywood in Lancashire and Hemel Hemstead. Since 1991 all such deliveries are subject to the "Quality Inspection Programme" created by McDonald's. This involves selecting specific numbers of sample cases from every single delivery into the distribution centres and opening them and checking them for specific quality criteria as detailed in their Quality Inspection Procedure Manual. This includes the taking of product temperatures and shelf lives which are also recorded in documentation before being accepted. Copies of reports on all loads are sent to McDonald's QA Department each week. Golden West Foods Ltd then deliver all products to our restaurants. They operate an extremely modern fleet of temperature controlled vehicles.
30. All deliveries on arrival at the restaurants are checked for product quality, temperature and shelf life prior to acceptance and the details are recorded in a Delivery Acceptance Log. Monitoring of standards in restaurants.
31. The Quality Assurance Department also has a role to play in the monitoring of product care in the restaurants. As described above, each month a particular restaurant is subjected to a "store audit" which involves physical and analytical checks on all food products. Attached as appendix 11 is a pro forma used to record results of the audit.
32. In addition, food quality is monitored by the Operations Department in an annual "full field" audit. This is described in more detail by Mr Wignall in his statement.
33. In addition to the checks described above, McKey provide a valuable service in monitoring standards in restaurants. They employ four full-time employees who travel to McDonald's restaurants checking the quality of McKey's products in the restaurants. They check products themselves, and the equipment used to prepare and store it, including grills, freezers (including calibration checks in each case) and anything else which might have an effect on the quality of the meat served to customers.
1. This statement is supplemental to my first statement nerved in January 1994 and is made in response to various new allegations made by the Defendants in their Re-Amended Defence served in April 1994.
2. It is alleged on page 3 paragraph 12 that in 1991/92 a female customer consumed McDonald's food containing a chicken cyst and received an out of court settlement. I have no knowledge of this incident and following a thorough search of the company's files I can find no record of this incident having taken place. I have also enquired of our suppliers, Sun Valley Poultry Limited, if they have any knowledge of this incident and they have informed me that they have no record of it and cannot even trace a complaint.
3. In paragraph 2 on page 4 it in alleged that in or around 1987, in Hackney, Environmental Health Officers from the Local Authority found the Salmonella virus in sewage outlet. of the local McDonald's store. There in no record of a visit or inspection by Environmental Health Officer at the Hackney store. However, Salmonella and/or other organisms are frequently present in all sewers and so such a discovery would not be surprising.
4. In paragraph 3 on page 4 the Defendants allege that Shaun Lynch discovered a live worm in a burger purchased at Woolwich McDonald's and that when he complained he was offered a free meal. It is correct that Mr. Lynch made a complaint of finding a live worm - allegedly 3-inches long (see newspaper article at Appendix 1). As can be seen from the company's letter to him (Appendix 1), this matter was taken up with our suppliers. Although I was not involved with the complaint or its investigation, I find it difficult to accept that the complaint can have been a valid one because (a) the lettuce has always been shredded and (b) in 1988 lettuce was vacuum packed which would have caused any animal life in it to suffocate.
5. In paragraph 4 on page 4 it is alleged that a customer discovered an inch long worm inside her "fish burger". Whilst every precaution is taken to remove cod worms from the filet-o-fish during the production process, it will be seen from the enclosed model purchase specification at Appendix 2 that the Ministry of Agriculture Fisheries and Food (MAFF) guidelines allow a tolerance for nematode worms of 3 worms per 71b unit of fish flesh. The company ensures that its suppliers conform to, if not exceed, this specification.
6. In paragraph 8 on page 4 it is alleged that in or around March 1989 some customers who consumed burgers at McDonald's on the Isle of Wight suffered food poisoning. I have no knowledge of this incident and I have searched the company's files and found no record of it. Further, I have telephoned the Manager of the Isle of Wight restaurant to ask if he had heard or had any knowledge of this allegation and he informed me that he had not.
7., Finally, it is said in paragraph 5 on page 6 that over 90 million chickens are raised in the U.K. each year to produce chicken McNuggets and McChicken Sandwiches. I have made an enquiry of Sun Valley Poultry Limited who inform me that for the U.K./Irish restaurants about 200,000 lbs of chicken breast meat per week are used for McDonald's Restaurants. Each bird yields approximately 1 lb of breast meat. Therefore the total number of birds needed is 10.4 million per year. This allegation is therefore incorrect.
January 12, 1994|
|supplementary statement signed:||
May 25, 94|
Appeared in court|
exhibits: Not applicable/ available
transcripts of court appearances: