Day 127 - 23 May 95 - Page 22
1 argument to them but they will follow the Company line.
2
3 Q. Then please turn over to 718. We observe as we go through
4 these, Mrs. Barnes, a number of them come from Frank Frost
5 who, as you have told us, is in the Northern region. The
6 Hopkins accident happened in the Northern region, did it
7 not?
8 A. It did, yes.
9
10 Q. This one which has a slightly later date appears to be more
11 or less identical, does it not, but it goes to different
12 people in Yorkshire and the North East, do you see that?
13 Anyway perhaps ---
14 A. Yes.
15
16 Q. -- it does not matter. I would like you to look with
17 particular care, please, at 719. It is said to come from
18 you. Would you, please, turn over to 720 and tell us
19 whether that is, indeed, your signature at the bottom of
20 the page?
21 A. It is my signature, yes.
22
23 Q. There is Richard Rowley, the Equipment Manager, on the
24 right-hand side, correct?
25 A. That is correct, yes.
26
27 Q. This, it appears, goes to all store managers; is that
28 right?
29 A. It does, yes.
30
31 Q. But those are Company store managers?
32 A. Yes, it is also copied to franchisees, the licensees in
33 there too.
34
35 Q. It is, is it? Yes, I see. I notice that it says: "Field
36 Consultants" in the third line at the end, do you see that?
37 A. I do.
38
39 Q. Are they the people that deal with the licensees?
40 A. They are Company employees that liaise with the
41 franchisees, and part of their role is to make sure the
42 franchisees are complying with Company systems and meeting
43 standards.
44
45 Q. Its date is 14th May 1991. I remind you that the Hopkins
46 accident took place on 12th October 1992. It is from you
47 and its subject is "Electricity at Work Regulations". Then
48 there is a box which says: "Danger". Beneath that:
49 "REMEMBER, ELECTRICITY KILLS" in capital letters. This
50 may be obvious, but forgive me: What is the purpose of
51 inserting that box in this memorandum?
52 A. Well, Richard and I both felt that it needed to be a
53 joint memo to give it some weight, but that we needed to go
54 even further to get the message over to our Operations
55 people, that electricity did have the potential to kill
56 somebody. Our Company then had been in place 15 years, and
57 it was very easy for somebody to turn around and say:
58 "Yes, but, you know, nobody has ever been
59 seriously injured by electricity at McDonald's", and that
60 is just really an example of how we were applying risk
