Day 217 - 09 02 96 - Page 46

 
 

                                                                  DAY 217
 
 
 
 
 
     1
     2   Q.   According to you, he works at the blood trough?
     3        A.  That is right.
     4
     5   Q.   After the animal has been hoisted?
     6        A.  Yes.
     7
     8   Q.   Look, please, look at line 14.  You say, after being asked
     9        to speak more slowly: "Well, the first area of concern for
    10        me was where it says blood hoist, meat hoist.  There is a
    11        man there who shackles the carcasses."  Mr. Morris: "This
    12        is just under cattle stun pen?"  You say: "That is right.
    13        At the beginning of the slaughter line, there is a man
    14        there who hoists the animal from its back leg on to a hook
    15        and chain and the carcass is hoisted up.  It is hanging
    16        from one of its back legs.  It is stunned at this point of
    17        time.  The same man, he has no access to hand wash
    18        facilities.  The hand wash facilities that you can see next
    19        to the legging transfer platform are high up, about eight
    20        feet high up from the floor.  So he has no access to those
    21        facilities.  He has no access to facilities to wash his
    22        hands or his instrument."
    23
    24        That is completely wrong, is it not?
    25        A.  No, it is not completely wrong.  We were talking about
    26        hand wash facilities as they are marked on the map.  Hand
    27        wash facilities that you can see there, they are up on the
    28        platform.  There is an apron wash there.  Apron wash is
    29        completely different from hand wash facilities.
    30
    31   Q.   I think you agreed with me not more than two or three
    32        minutes ago that you can wash your hands in the apron wash?
    33        A.  Yes, of course you can wash them.  You can rinse them
    34        there, but you cannot wash them.  You do not have access to
    35        soap, and you do not have access to similar type of
    36        facility as hand wash facilities; and that is what I was
    37        talking about in this statement.  I was not taking about an
    38        apron wash.
    39
    40   Q.   You said that he had no access to facilities to wash his
    41        hands or his instrument.  Do you see the sterilizer by the
    42        apron wash on the ground?
    43        A.  But sterilizer is not meant to be a washing facility.
    44        You are not meant to be put a soiled instrument in it,
    45        because then you are making the sterilizer inefficient in
    46        the long run.  You are meant to wash your instruments first
    47        before you put them in the sterilizer for it to function
    48        properly.
    49
    50   Q.   Why did you not tell us on the last occasion you were 
    51        here: "I am sorry, this plan is wrong.  There is an apron 
    52        wash and a sterilizer on the grounds within (according to 
    53        you) two or three metres of the bleed hoist"?
    54        A.  Was it not marked in the old map?
    55
    56   MS. STEEL:   It was.
    57
    58   THE WITNESS:   It was marked in the old map, I remember.
    59        Because I remember particularly talking about hand wash
    60        facilities and Mr. Morris asking me about hand wash
 
                                      46