Day 103 - 14 Mar 95 - Page 25

     
     1   Q.   So that in the same way as the burgers, the hamburgers,
     2        are, if you like, minced up, does the same process take
     3        place with the chicken?  It is not actually minced but it
     4        is -----
     5        A.  The whole meat is tumbled in -- but I am -----
     6
     7   Q.   So it is mixed up with lots of different birds meat comes
     8        together?
     9        A.  Yes.
    10
    11   Q.   So any contamination will, basically, be spread to all the
    12        meat?  If there is, for example, Salmonella contamination
    13        in a bird it will be mixed up with all the other?
    14        A.  Of course.
    15
    16   Q.   On the next page -----
    17
    18   MR. JUSTICE BELL:  Presumably, that shows the need not just to
    19        have a high or a low but an average as well?
    20        A.  Yes.
    21
    22   Q.   So that gives you some indication because the average might
    23        be nearer to the high or nearer to the low?
    24        A.  That is right.
    25
    26   Q.   So the high and the low do not necessarily give you an
    27        indication of what it is likely to be like once you have
    28        churned it all together.  Your average does give you some
    29        kind of indication?
    30        A.  Yes, that is a fair analogy, yes.
    31
    32   Q.   In addition to which subsequent forms of contamination
    33        might have to be taken into account as well?
    34        A.  Yes, that is correct.
    35
    36   Q.   But when you are looking at what you are likely to get from
    37        the raw material, the average is important?
    38        A.  Yes, that is correct, yes.
    39
    40   MR. MORRIS:  If we go to the next page, it just may be worth
         noting.  Do you have the next page?
    42        A.  I have.
    43
    44   Q.   Just in the bottom left-hand box again, we have the
    45        following week.  By some amazing coincidence, the VDB is
    46        exactly the same, high, low and average.  Can you explain
    47        how that could have happened?
    48        A.  Yes, I can do.  I mean, I am only guessing here but we
    49        do not take meat from these suppliers, every supplier every
    50        week.  Van der Brink(?) which that refers to is one of 
    51        smaller suppliers. 
    52 
    53   MR. RAMPTON:  My Lord, in fact if one looks at those charts one
    54        sees VDB contributed no bins for all of those three weeks?
    55        A.  So, all they have done is taken a supplier average from
    56        previous occasions.
    57
    58   MR. MORRIS:  So it is a running average, is it, or a running
    59        high.
    60