Day 085 - 08 Feb 95 - Page 27


     
     1        our customers.
     2
     3   Q.   I am sorry, I am talking about employees.
     4        A.  Employees' health?
     5
     6   MR. JUSTICE BELL:  Health and safety of employees.
     7        A.  Employees' health and safety.
     8
     9   MR. MORRIS:  Have you made any criticisms of the present
    10        company's setup in your six months in your post?
    11
    12   MR. JUSTICE BELL:  Have you made any criticisms or suggestions
    13        for alteration or improvement?
    14        A.  No, I have not.
    15
    16   MR. MORRIS:  If I put it to you that the company has a
    17        complacent attitude towards employee safety, would you
    18        agree with that?
    19        A.  Absolutely not.  I think it could not be further from
    20        the truth.  They are substantiated by reading this document
    21        that I have not seen before regarding all the
    22        recommendations, and my current understanding, seeing that
    23        a lot of those recommendations are now currently in place,
    24        demonstrates that we are not complacent in the least.
    25
    26   Q.   If I put it to you that the setup and the pressure to work
    27        hard and the under-staffing in the stores creates an unsafe
    28        environment for employees to work in, would you agree with
    29        that?
    30        A.  No, I would not agree with it.
    31
    32   Q.   One further question, a factual question:  Have you ever
    33        seen a memo or a statement or a concern or a paragraph in a
    34        report about the understaffing levels in restaurants
    35        contributing to safety problems for employees?
    36        A.  No.
    37
    38   MS. STEEL:  Could you get yellow bundle VII, please?
    39        A.  Which part of yellow VII?
    40
    41   Q.   Tab 3, the statement of David Wignall.  The precautions
    42        that are listed to minimise the risk of ---
    43
    44   MR. JUSTICE BELL:  Can you give him a reference?
    45
    46   MS. STEEL:  -- food poisoning.  It is the first page of the
    47        statement, page 50.  Those three things that are listed,
    48        what system of checks are in place to make sure that they
    49        are actually carried out?
    50        A.  The cleaning and maintenance of equipment?  The 
    51        cleaning and maintenance of equipment, there is a planned 
    52        maintenance calendar which used to be in use which has now 
    53        been transferred on to the back of the daily product safety
    54        check list which details which piece of equipment should be
    55        cleaned, and recommendation at the time of the day for them
    56        to be cleaned, and also there is a space for signature for
    57        people to sign that they actually carried out that task.
    58
    59   Q.   Whose responsibility would that be to sign it?  Is that
    60        just undertaken by a crew member or is that by management

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