Day 094 - 01 Mar 95 - Page 06

     
     1        there any other kind of document which will give me any
     2        more assistance, any kind of US DA check or filling in a
     3        form, which would tell one just what was wrong with
     4        equipment disassembly, or anything of that kind?
     5        A.  Yes, there is a -- if this report generates, if the
     6        number under the SPL is, if it is high, then it triggers
     7        what is called an intensified inspection.  So, instead
     8        of -----
     9
    10   Q.   You see, you have accepted from Mr. Morris that you may
    11        only need to have one weak link in the chain for the chain
    12        to break, in effect?
    13        A.  That is correct.
    14
    15   Q.   One of the links in the chain, I suppose, is the
    16        preoperation sanitation of facilities and equipment ---
    17        A.  That is correct.
    18
    19   Q.   -- you might tell me that it would be more important if
    20        another link were weak, but there is a weak link.  Whether
         they are vital noncompliances or not, there is a total of
    22        just over 70 per cent noncompliance there ---
    23
    24   MR. MORRIS:  That was 95 per cent actually.
    25
    26   MR. JUSTICE BELL:  -- no, 70 per cent -- 70.81 per cent in that
    27        link of the chain, the preoperation sanitation?
    28        A.  Now, what we have to keep in mind that this does not
    29        represent a risk.  These are non-conformities.
    30
    31   Q.   What you are saying is non-conformity does not necessarily
    32        involve a risk?
    33        A.  That is correct.
    34
    35   Q.   Is there a similar kind of printout from which I could get
    36        information as to whether there was a risk and, if so,
    37        whether it is a small risk or a substantial risk?
    38        A.  Yes.  So, let me see if I can explain how this works
    39        and how it generates other -- the report that we are
    40        looking for.  If this number, the statistical process
         level, is high enough, it goes into a computer and it
    42        triggers the intensified inspection.  That means -----
    43
    44   Q.   Do you know if it is any figure within the section or the
    45        figure at the end of the printout?
    46        A.  No, what this tells me is that this plant, and
    47        I confirm with plant with Tyson, and during my
    48        cross-examination I testified -----
    49
    50   Q.   I cannot listen to that.  You tell me what the 
    51        understanding is in relation to that? 
    52        A.  OK.  What this tells me is that this plant has never 
    53        been placed on intensified inspection.
    54
    55   MR. MORRIS:  So, despite this 95 per cent non-conformance level
    56        of preoperation sanitation of equipment disassembly,
    57        intensified ---
    58        A.  Inspection.
    59
    60   Q.   -- inspection was not implemented?