Day 101 - 10 Mar 95 - Page 04


     
     1        place.
     2
     3   Q.   But that does not extend to all the more senior members of
     4        the Quality Assurance Department being aware of all the
     5        investigations or certainly all the major investigations?
     6        A.  Well, I was aware of the investigation into the Preston
     7        incident.  It is just that I was not involved in it.
     8
     9   MR. JUSTICE BELL:  If I might suggest, it might be more
    10        productive, if you do want to pursue this line, that you
    11        just put to him what you suggest should be done because the
    12        rest is argument from the information which you already
    13        have.  I am not suggesting there is anything more to put.
    14        You may feel that -- I am not suggesting you have -- that
    15        you have answers and you can mount your argument on that.
    16        But if there is some specific matter of the fact you want
    17        to bring out as to what was or was not done so you can
    18        mount an argument in the future, then do so.
    19
    20   MS. STEEL:  Right.  When these investigations are made, does the
    21        company actually look into common denominators between each
    22        alleged complaint?
    23        A.  Is it easier if I tell you what we would do if there
    24        was a food poisoning investigation?  Would that make things
    25        quicker?
    26
    27   MR. JUSTICE BELL:  Do that quite shortly and then Ms. Steel can
    28        ask you what you do or do not do off the back of that?
    29        A.  Well, what we do is we would go back, and I mentioned
    30        all the procedures that we had in place.  We have
    31        documentary records of all those procedures, so we would go
    32        back through the line and check those records, so that
    33        would include the records in store that they keep which
    34        I think have been discussed earlier, Daily Product Safety
    35        Check List, which records all the cooking times, the
    36        temperatures, the freezer temperatures, all the operations
    37        in-store.  Those are the controls in-store that we would
    38        have.  Those would all be checked.
    39
    40        There would be a check on Delivery Acceptance Log which is
    41        the log that is filled in when the products are delivered
    42        to the restaurant, so that would be checked.  We could then
    43        go back -- this is assuming of course we have the code of
    44        the product -- we can then trace that back to the
    45        distribution centre and find out when that came in.  We can
    46        check the logs that they keep at the distribution centre
    47        there.
    48
    49        We go right the way back to production.  We can check
    50        records, all the QC records through the production.  They 
    51        keep library samples at all our production facilities of 
    52        every code of product, so we can actually pull, if we have 
    53        the code, pull from store a very similar product and have
    54        that checked microbiologically.  That is what we can do
    55        documentary.
    56
    57        The other thing we would do would be discover from another
    58        record that are kept who was involved, what person was
    59        involved, in cooking at the particular time.  They would be
    60        questioned, their training records would be looked at.

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