Day 018 - 26 Jul 94 - Page 19

     
     1
         Q.   If I am right, say so; if I am not, tell me so.
     2        A.  You are doing well.
 
     3   MR. JUSTICE BELL:  0.17 is 17 in every 10,000, is it not?
              A.  That is correct.
     4
         MR. RAMPTON:  As opposed to the mean, which is 19.
     5        A.  Yes.
 
     6   Q.   What, in your view, was the principal cause of that
              relatively small number of dead on arrival at Sun Valley?
     7        A.  The cause of fatal trauma from the table shows
              ruptured liver as being the principal cause of fatal
     8        trauma.
 
     9   Q.   How did that come about?
              A.  A good question.  I am not entirely certain.  There
    10        are two types of liver trauma in terms of the anatomy.
              I am not sure what actions cause each type, so I do not
         know.
 
    12   Q.   What about the construction of the cages, or whatever they
              are, in which the Sun Valley birds are transported from
    13        their unit to the slaughter house?
              A.  That could be a factor but I do not know; it could be.
    14
         Q.   Is it a particular or peculiar kind of container?
    15        A.  It is.
 
    16   Q.   What is it called?
              A.  Compared with the other plants in the survey, it is.
    17        It is in the design of a drawer which would fit into a
              chest of drawers, so the birds are put -- the drawer is
    18        pulled out, the birds are loaded in.  When it is full, the
              drawer is closed.  That forms part of, as I say, a chest
    19        of drawers which is called a module.
 
    20   MR. JUSTICE BELL:  Is it something like trays of bread in a
              bakers' van, which you slide in?
         A.  It sounds like it, but I am not totally familiar with
              bakers' vans.
    22
         Q.   I am just trying to picture it.
    23
         MR. RAMPTON:  It is made of plastic, I think?
    24        A.  The drawers are, yes.
 
    25   Q.   Do you have (and again this is a question I have asked
              before and will ask again) any criticism of that 
    26        particular design of crate or container? 
              A.  There is one weakness in the design, yes, and that is 
    27        the way that -- it is the design of the upper lip of the
              front of the drawer.  What is really needed there is a
    28        flexible boarder such that if a bird has its head sticking
              up when the drawer is closed, the head or neck will not
    29        get crushed; as it is the clearance between the drawer and
              the frame of the drawer is too small and you are prone to
    30        getting crushed skulls in that situation.