Dr Mark Winter

In relation to para 11 of your statement - Did you explain the relative viral infections risks of Cryo and Concentrate with patients?

• In relation to para 29.1 - Would the alleged problems associated with cryo use have been less notable than the subsequent problems associated with concentrate use, in particular, the problem of HIV infection?

• In relation to para 30.1 - What was the financial difference between home concentrate use compared to in-hospital use of cryo?

• In relation to para 30.2 - Do you think this policy should have been changed or reviewed, particularly as the potential scale of the HIV problem became more apparent?

• In relation to para 32.1 - Did you make any request for increased allocation of BPL Factor VIII during this time?

• In relation to para 32.2 - Can you confirm that you had access to and only used heat-treated Factor IX from May 1984 (note: I don’t think HT FIX was available until a good year or more after this)

• VERY IMPORTANT: In relation to para 35.3 (Cryo) - Is it the case that before the introduction of concentrates, severely affected patients were treated with cryo?

  • Were you aware of any single case before this time, where the cryo treatment itself had resulted in death?

  • You say cryo was less effective than concentrates, but do you agree that cryo still had the effect of raising levels of Factor VIII in severely affected patients? So, therefore, it was effective?

  • Did you consider the need to store treatment in a freezer, to pose more of a problem than infection with HIV?

  • Did you consider the preparation of cryo, to pose more of a problem than infection with HIV?

  • Are you aware of any published data to support your claim that cryo side effects were “common”

  • Is it true that most cryo use cases did not cause side effects?

  • In what proportion of cryo use cases would you estimate side effects occurred?

  • What proportion of cryo side effects do you estimate were more serious than HIV infection?

  • Are you aware of any published data to support your claim that cryo was in short supply?

    • If there was a short supply of cryo, could this have been rapidly increased by utilising plasma from reduced production of concentrates?

• VERY IMPORTANT: In relation to para 35.4 - You present suspension of all treatment as a possible option but not the suspension of only concentrates as an option, why?

  • Is it true that suspension of only concentrate treatments would have been preferable to suspension of all treatment?

  • Is it true that another possible option would have been to suspend concentrates while allowing cryo and other forms of treatment to be used?

  • Would the risk of not treating patients at all, have been greater than the risk of treating patients only with cryo?

• 35.4 again - Are you aware of why commercial companies had introduced viral inactivation processes when BPL had not?

  • Do you know why BPL was lagging behind the progress made by commercial companies?

• 60.3 - Was this also your personal view?

• 112 - Could you elaborate on the problems AIDS had caused with coroners and undertakers?

• 124.2 - On what evidence do you contend that BPL concentrates were derived from pools of 20,000 donors?