Day 127 - 23 May 95 - Page 59


     
     1        is -- well, two things -- the first is that the rate of
     2        accidents recorded in that book works out, I think, at
     3        about just over two a month.  Can I ask you, is that
     4        typical of the Company's business?  Is it more, is it less,
     5        or what?
     6        A.  I would expect, if the crew and the managers were being
     7        really diligent, for there to be around about somewhere
     8        between "eightish" a month, something like that. However,
     9        it does depend on, first of all, the crew members making
    10        the managers aware or going and getting the accident books
    11        themselves if they have, say, a minor accident or a minor
    12        burn.
    13
    14   MR. JUSTICE BELL:  How many a month did you say?
    15        A.  About eight, I would have thought.
    16
    17   MR. RAMPTON:  I can tell you now, Mrs. Barnes, that is the
    18        figure Mr. Atherton gave us.  He thought it was around
    19        eight a month.
    20        A.  I am basing that on about a hundred a year or two a
    21        week.
    22
    23   Q.   If we do a little bit of arithmetic, eight a month makes
    24        nearly a hundred a year, does it not?
    25        A.  Yes.
    26
    27   Q.   Is that right?
    28        A.  Yes.
    29
    30   Q.   96; call it 100.
    31        A.  100, yes.
    32
    33   Q.   If there are, what, how many on average crew per
    34        restaurant?
    35        A.  50 to 80.
    36
    37   Q.   If we call it 50, if it was more the figure would be lower;
    38        but let us call it 50; we get around two of these accident,
    39        report book type accidents per crew member per year; is
    40        that right?
    41        A.  Yes.
    42
    43   Q.   Which, if there were at, I do not know, 1990, something
    44        like, I do not know how many restaurants there were,
    45        but -- how many of these kinds of accidents, not the
    46        serious ones but the more trivial ones, do you think were
    47        occurring annually in, say, 1990, 1991 throughout the
    48        operation?
    49        A.  Well, if, say, we had about 25,000 employees then and
    50        we had two a year that would be about 50,000. 
    51 
    52   Q.   About 50,000.  The other question, or one of the other 
    53        questions I had about this accident book is that one
    54        notices that it covers the years 1984 to 1992?
    55        A.  Yes.
    56
    57   Q.   If the accidents were happening at the rate of eight a year
    58        rather than two it would not have been possible, I suppose,
    59        would it?
    60        A.  No, they would have got through a lot quicker.

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