Day 139 - 21 Jun 95 - Page 25
1 has been cleaned. But what they do is, cleaners and USDA
2 people then go around together, inspecting every nook and
3 cranny of this facility, to make sure that before the plant
4 begins to operate in that day, it completely has been
5 cleaned and sanitised before any operations can begin.
6 What they do, my Lord, is, the USDA inspectors take notes
7 of things that they want to make sure have been gone over
8 again and have been sanitised before that line is to
9 operate. They then use their checklist to, in fact,
10 re-inspect what the cleaners have done, my Lord, before
11 that operation can open.
12 The USDA has to approve that that plant is totally clean
13 and sanitised before anything can begin in that plant.
14
15 What they took here were those pre-inspection notes, made
16 them appear to be conditions that existed when that plant
17 was in operation; and that is what was done.
18
19 MR. MORRIS: So -----
20 A. If I might, my Lord, operations reports that they did
21 have showed a totally spotless, totally clean environment
22 at all times; and I might also add that if it was not, the
23 USDA inspectors who had the power to shut that plant down
24 immediately if they saw anything they did not like.
25
26 Q. If you would look at the fifth paragraph in there?
27 A. Fifth paragraph where, sir?
28
29 Q. On page 1394. It specifies these are from daily
30 pre-operation sanitation reports filed by the USDA. So
31 that is correct; what it says there is correct, yes?
32 A. You have to -----
33
34 Q. Is it correct?
35
36 MR. RAMPTON: My Lord, I do object. I have had this throughout
37 this case, this awful business of lifting a sentence out of
38 context. The witness must be allowed to be read the whole
39 document and then a sensible question asked about the
40 effect of the document.
41
42 MR. MORRIS: That is what you said.
43
44 MR. JUSTICE BELL: Just pause a moment. You can certainly ask
45 about any specific part of the document.
46
47 (To the witness) You answer Mr. Morris' question, please,
48 Mr. Stein, and add any further comment you wish to it, to
49 your answer.
50
51 MR. MORRIS: What they say there, the daily pre-operation
52 sanitation reports filed by the USDA Food Inspection Safety
53 Division, they are what you said, what you were just
54 describing, the pre-operation sanitation?
55 A. I was describing -- yes, I did describe pre-operations,
56 yes.
57
58 Q. And this is what is contained in this leaflet?
59 A. You have to look at the context of this entire
60 leaflet. You know, you are disputing something that George
