Day 128 - 24 May 95 - Page 20


     
     1        then.  Normally, we would meet with the Manager before the
     2        Environmental Health Officer arrived, so we could go
     3        through all the details with them beforehand.  So
     4        I certainly would have expected Mark to go through it all
     5        with the Manager.
     6
     7   Q.   You do not know whether any supervisory staff got a warning
     8        about not making, they should not make crew members work in
     9        ways that was a danger to their safety?
    10        A.  I do not know whether they had a formal warning, no.
    11        I would have expected the Restaurant Manager to have taken
    12        it up with his management team.
    13
    14   Q.   The second letter from Mark Hathaway on 2nd August 1993, he
    15        says about a second clamshell grill unit being supplied on
    16        5th August.  That would have been one and the same, would
    17        it?
    18        A.  Well, what we had in place in quite a lot of stores at
    19        that time was one full clamshell grill for the regular meat
    20        patties, and a mini clamshell for the quarter pounders.
    21        This would indicate they were having a second full
    22        clamshell.  It does not make it clear, really, from
    23        Mr. Nelson's letter which of the two grills are causing the
    24        problem.
    25
    26   Q.   So it was supposition on your part that it referred to a
    27        quarter pounder grill?
    28        A.  He does say "mini clamshell", which is our terminology
    29        for the quarter grill, which I am basing that on.
    30
    31   Q.   Do you think it is acceptable that the Company took the
    32        better part of three months to do something about this
    33        problem of employees getting burnt?
    34        A.  It depends really the time line that occurred, and we
    35        cannot really tell from looking at this, but it might have
    36        been difficult for Mark to meet up with Mr. Nelson
    37        straightaway.  It then would have needed time to arrange
    38        for the grill to be ordered.
    39
    40        Normally, I would expect us to reply, these days in
    41        writing, within two weeks to an Environmental Health
    42        Officer, unless a meeting was taking place, and then within
    43        a few working days after the meeting to have a letter put
    44        together, but I really cannot remember the specifics of
    45        this particular contact.
    46
    47   Q.   Mr. Nelson, mentions his investigations in his letter of
    48        19th May.  Presumably, he would have been to the store to
    49        make those investigations?
    50        A.  I would have thought he would, yes. 
    51 
    52   Q.   It sounds like he has visited the store from the letter, so 
    53        the store management would have been aware of the problem
    54        at that time?
    55        A.  They would, yes.
    56
    57   Q.   They could have done something about it much sooner, could
    58        they not?  They could have ordered another clamshell grill
    59        to reduce the pressure to the speed at which cleaning had
    60        to be done, for example?

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