Day 072 - 12 Jan 95 - Page 44


     
     1        A.  What does what mean to me?
     2
     3   Q.   "At least one block in every direction"?
     4        A.  As I said, I agreed it would have been interpreted as
     5        going north of the Kings Road as well.
     6
     7   Q.   So you would recognise that you are in contravention of
     8        what is stated in this Operations Manual then?
     9        A.  From this statement, I would not be following their
    10        guidelines.
    11
    12   Q.   Turn to page 75, under "exteriors" it says:  "Keep the
    13        parking lot and a one block radius from your lot free of
    14        environment/index.html">litter."  Again I have looked right through the parts that
    15        we have of this document and I cannot see anything in there
    16        about trash walks being undertaken on a half hourly basis.
    17        Do you know in this document whether it makes that
    18        direction?
    19        A.  I know that I get the half hour from the British OCL,
    20        from the English, the British version of the Observation
    21        Check List.  I was taught that as a trainee and I am not
    22        100 per cent sure if it is in this manual, but I know that
    23        is the British standard but I am not sure where it is
    24        documented apart from on the OCL.
    25
    26   Q.   Does every store have a maintenance person?
    27        A.  No.
    28
    29   Q.   They do not?
    30        A.  I would not have thought so.  I know of one of the
    31        stores that has not got one.  Is this exclusively to the
    32        restaurant or it could be a maintenance person that works
    33        between a number of restaurants?
    34
    35   Q.   There is a job description title for a maintenance person,
    36        is there not?
    37        A.  On which page?
    38
    39   Q.   It is not in this document.  It is in another document.
    40        But there is a person employed by McDonald's as a
    41        maintenance person; it is a position?
    42        A.  Yes, I believe so.
    43
    44   Q.   But you say they do not have them for every store; there
    45        might be one shared between -----
    46        A.  For a lot of the maintenance jobs salaried managers are
    47        qualified to complete them.
    48
    49   Q.   On page 54 of this document it has a section on maintenance
    50        person and responsibilities.  The third paragraph says: 
    51         "Outside the restaurant general cleanliness includes 
    52        cleaning and upkeep of the building, parking lot and 
    53        landscaping as well as all areas in proximity to the
    54        restaurant, side walks, kerbs and adjacent land.
    55        Altogether general cleanliness is a big job and an
    56        important one.  For this reason the maintenance person must
    57        be chosen with care."   But you say that not all stores
    58        have maintenance people?
    59        A.  Well, all stores complete maintenance but it does not
    60        mean that they necessarily have one person specifically for

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