Dr Tony Napier

WS Questions

1. P5 - He says he has not been involved in any litigation. This is not true. See documents referred to in my oral evidence - Section 129 on the transcript.

2. P104 - Can he explain what he means by “limited accommodation”?

3. P125 - Can he explain what became of the red cells?

   1. And how standard whatever became of the red cells was across the UK to his knowledge?

4. P127 - How was “demand” assessed?

5. P127 - He says production was “very labour-intensive”. Can he explain why there is a tension between his comment and the medical literature, for example…

   1. "Cryoprecipitate is inexpensive because the production of this Factor VIII preparation is considerably less complicated than any other procedure of purification so far used" - Link Removed

   2. "cryoprecipitate can be prepared easily and economically by hospital blood banks" - Link Removed

   3. "Cryoprecipitate is also relatively simple and inexpensive to prepare" - Link Removed

   4. "it is simple and not too expensive, requiring neither costly apparatus nor special technical skills" - Link Removed

   5. "The manufacturing procedure is quite simple, requiring no special skill or training"- Link Removed

6. P131 - Can he confirm that here, he appears to be saying that it was in “the early 1980s” that WRTC could/should have "increased its manufacture of cryo"?

   1. Does he know if that did happen?

7. P134 - It would be worthwhile (as I don’t think we have done this with any witness yet) to show him the described side-effects on the FVIII concentrate labels eg chills and ask him if these were any different to Cryo. Hence is this even an argument?

8. P135 - When he says “early years of haemophilia treatment” can we clarify he is referring to the mid/late 60’s, as he is talking about Cryo?

   1. And that the treatment of haemophilia had existed long before this? Albeit not with cryo?

   2. Does this perhaps reflect a lack of knowledge on his part as to the long history of the treatment of haemophilia?

   3. Would it be more accurate to say the early years of his career, rather than haemophilia treatment?

9. P140 - Are we to understand from this that prior to HIV, safety was not the “paramount concern”?