Day 103 - 14 Mar 95 - Page 08

     
     1   MR. RAMPTON:  My Lord, I am told it was 15.  I have mine loose.
     2        I believe, although I am not sure, Dr. Pattison has it in a
     3        loose bundle.
     4
     5   THE WITNESS:  Yes, I have it here.
     6
     7   MS. STEEL:   It is the Health & Safety Executive; is that right?
     8        A.  I do not know.  I have never seen the document.
     9
    10   Q.   You have never seen it before?
    11        A.  Not at all.
    12
    13   MR. JUSTICE BELL:  I have not got it.  I am looking at tab 15.
    14        It has a lot of documents in it.  Which part do you want us
    15        to look at?
    16
    17   MS. STEEL:   It has a picture of a chicken on the front.
    18
    19   MR. JUSTICE BELL:  Yes, I have the document.
    20
    MR. RAMPTON:  Page 10 at the bottom, I guess.
    22
    23   MS. STEEL (To the witness):  You have never seen this before?
    24        A.  No.
    25
    26   Q.   Have you seen any Health & Safety Executive documents in
    27        relation to the poultry industry?
    28        A.  I do not think so, no.
    29
    30   Q.   Would that not be something that would concern your
    31        department?
    32
    33   MR. RAMPTON:  My Lord, I am not at all sure that the health &
    34        safety of the employees at Sun Valley has anything to do
    35        with this case at all.  For all I know, they are all dying
    36        of chicken smell, but it has nothing to do with this case
    37        whatsoever.
    38
    39   MS. STEEL:  Is that nothing that would concern your department?
    40
    MR. RAMPTON:  No, my Lord.  I have made an objection on which
    42        I would invite your Lordship to rule.
    43
    44   MR. JUSTICE BELL:  I rule against you because it seems to me he
    45        can fairly be asked whether this is a document which he has
    46        seen, and can fairly be asked if not, why.  There may be a
    47        very ready explanation to that.  As I understand it, the
    48        questioning is not going to the safety of employees at Sun
    49        Valley but the question of ammonia.
    50 
    51   MR. RAMPTON:  That I understand.  The last question was whether 
    52        he was concerned about the safety of his employees. 
    53
    54   MR. JUSTICE BELL:  You express it a better way.
    55
    56   MS. STEEL:  I did not say whether he was concerned.   I said:
    57        "Is that not something that concerns your department?"
    58
    59   MR. JUSTICE BELL:  That is another way of putting the same
    60        thing.  You can get to the same end via a route which does