Day 067 - 15 Dec 94 - Page 15


     
     1        copy of it in front of him?  It seems to me only right.
     2
     3   MR. JUSTICE BELL:  Yes, it is yellow IX.
     4
     5   MS. STEEL:  Turn to page 34 of the bundle.
     6        A.  Page 34.
     7
     8   MR. JUSTICE BELL:  Mine is not paginated.  Have you got a
     9        paragraph number?
    10
    11   MS. STEEL:  It is the second page of the first statement.
    12
    13   MR. JUSTICE BELL:  Divider 4.
    14
    15   THE WITNESS:  I have it.  At point No. 5, are you referring to
    16        that one?
    17
    18   MS. STEEL:  No, point 4 at the top of the page, do you not
    19        remember saying that the company carries out audits?
    20        A.  I did not say that -- I am just looking.  I want to
    21        make sure I have the same access to the information that
    22        you have and looking for it.  So, you are looking at point
    23        1 as the first page?
    24
    25   Q.   Paragraph 4, but I am specifically looking at the part of
    26        paragraph 4 that is on the second page of the statement.
    27        A.  OK.  At the top of the page?
    28
    29   Q.   Yes.
    30
    31   MR. JUSTICE BELL:  Ask the question again; he is waiting for
    32        you.
    33
    34   MS. STEEL:   What do these audits consist of?
    35        A.  Audits?  OK.  We visit a plant.  Our main concern is --
    36        let me use an example of a beef pattie supplier.  I would
    37        visit a plant.  Like I said, our major concern is food
    38        safety, so we look at the hygiene in the plant; we look at
    39        how they clean the plant; we look at how the hygiene
    40        practices of the employees; we look at their pest control
    41        programmes; we look at their quality control programmes,
    42        including the records that they have; we spend some time
    43        with their people so we can have a better idea of their
    44        attitude towards quality, towards safety; we look at the
    45        raw materials, the quality of the raw materials; we look
    46        for, let us assume, beef, we like for signs of stress, the
    47        colour of the meat; we look for signs of abuse of the meat;
    48        we look at the microbiological data; we look at the
    49        products that are -- I would look at products that they
    50        currently have in the market.  I take samples, send them, 
    51        have them analysed in the lab and I do that over a period 
    52        of time to get an estimation of their quality and the 
    53        consistency of their operations.  We have a check list that
    54        will guide us through the process.  We look at everything
    55        from incoming raw materials, we look at ingredients -----
    56
    57   Q.   So you have a form that you fill in, do you?
    58        A.  Yes, we do, plus we have the -- we also do evaluations
    59        that the form will not tell you, such as the attitude of
    60        the people there.  We would look at a lot of things.

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