Day 095 - 02 Mar 95 - Page 07

     
     1        pieces.  If that increases, if it is too much pressure that
     2        increases the temperature, but again we are talking about
     3        very, very low pressures, low temperatures.
     4
     5   Q.   Then there is, "Overall appearance of plant has improved in
     6        both cleanliness and attention to detail".
     7        A.  In that specific case it is actually -----
     8
     9   MR. JUSTICE BELL:  You have not been asked a question yet.
    10        A.  Oh, sorry.
    11
    12   MS. STEEL:  If a plant is absolutely fine and is very clean and
    13        up to what you consider your standards to be, would the
    14        form say so?
    15        A.  I never seen anybody doing so.  We are always looking
    16        for improvement.  We are never going to reach a point to
    17        say:  "We are fine; we cannot improve".  We are never going
    18        to be at that point.  There is never enough things that you
    19        can do to improve your plant in terms of cleanliness, in
    20        terms, in this case, it is attention to detail.  He is not
         talking about the critical things, things about the detail
    22        that gives you a motivation to keep everything clean,
    23        everything in order.  I never seen a report that says:  "We
    24        are fine; there is nothing else we can do".  That is the
    25        wrong attitude.
    26
    27   Q.   So, as long as the supplier is improving on the levels of
    28        cleanliness, you would tolerate a situation that you would
    29        consider below what you would be aiming for?
    30        A.  Sorry, I did not understand your question.
    31
    32   Q.   You have standards that you aim for, where you ask your
    33        suppliers to aim for?
    34        A.  Yes, we do.
    35
    36   Q.   If the suppliers do not meet those standards, you would not
    37        automatically cut them off as suppliers?
    38        A.  No.  What we do, we do not work that way.  We have
    39        minimum standards, that if they break those, yes, I could
    40        probably say there are grounds for dismissal or
         disapproval.  We have those.  We do not have in any many
    42        ways specifications to determine the exact level of
    43        cleanliness for a simple reason, we do not want to regulate
    44        things that need to be improved consistently, such as we
    45        went through, for instance, the stunning of birds.  We do
    46        not want to regulate that because once you regulate
    47        something, once you put a limit, the supplier, all he has
    48        to do, whether or not it is right, is to meet those.  We
    49        want the suppliers to continually improve.  If we put a
    50        limit, we put a limit on innovation, we put a limit on 
    51        technology, we put a limit on new development and 
    52        improvement.  We do not do that.  We do have certain 
    53        minimums that they have to meet, that we expect every
    54        supplier to exceed our expectations every single day.
    55
    56   Q.   Turn over to the second page.  This is actually July 1994.
    57        A.  Yes.
    58
    59   Q.   Is this a form that would be used on a follow-up visit?
    60        A.  This is a form that is used to -- we verified our HACCP