Day 086 - 09 Feb 95 - Page 29


     
     1   MR. MORRIS:  Can I ask you just one outstanding question, if
     2        I could just butt in there.  All fat filtering machines now
     3        do have residual current devices, yes?
     4        A.  Yes, I believe all the equipment that we have, portable
     5        equipment has it -- no, all the equipment has it.
     6
     7   Q.   All equipment has it?
     8        A.  All equipment has got RCD.
     9
    10   Q.   That device costs about £25, something like that?
    11        A.  I do not know the cost.  I would not dispute that.
    12
    13   Q.   I will not refer to it but it was in volume XIII, tab 52,
    14        page 780.  It was a memo the day after the accident.  It
    15        says it costs £20 at that time.  Thank you.
    16
    17   MS. STEEL:   Can you turn to page 521, please?
    18
    19   MR. JUSTICE BELL:  That is not £20 for every machine?  That is
    20        just the thing I have on my electric lawn mower and I stick
    21        in the socket and then the plug into that?
    22        A.  It is similar to that, similar to that on each piece of
    23        equipment.  521?
    24
    25   MS. STEEL:  Yes.  It is upside-down for some reason.
    26        A.  I was going to say on mine it is upside down as well.
    27
    28   Q.   You were talking about travel paths yesterday, is this the
    29        typical travel path?
    30        A.  Yes, each stores will be different because of the
    31        layout.  That is just a schematic generalisation on a
    32        travel path.
    33
    34   Q.   There is nothing in there about health and safety?
    35        A.  Travel path is where you walk around, and I will check
    36        it through.  Crew positioning could be construed as health
    37        and safety as who is in charge.
    38
    39   Q.   How could -----
    40        A.  If they are positioned safely or not safely, that there
    41        is someone in charge of the area that they are being
    42        supervised; checking the pavements, again that could be
    43        health and safety, to make share sure that they are in safe
    44        condition; again the backyard, if it is clean and
    45        organised, if it is, then that would be safe; floor control
    46        in itself, that is one of the major contributors to health
    47        and safety that we are looking that people are working
    48        effectively and safely; again lobby, that the floor is
    49        clean and dry, that is checking, you know, on a health and
    50        safety matter. 
    51 
    52   Q.   That would be something that would affect the safety of the 
    53        customers?
    54        A.  Yes, when you are out in the dining area, that is
    55        correct; kitchen/back room, again cleanliness, the fact
    56        that it is clean, organised -- I have got a bit missing in
    57        the punching of the paper.
    58
    59   MR. JUSTICE BELL:  "Sinks"?
    60        A.  Yes, sinks, again the freezer, the walk-in

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