Day 136 - 16 Jun 95 - Page 22
1
2 Q. If we look in the minutes for 7th December 1992 -- these
3 are not numbered by page -- it is about a third of the way
4 through that bunch of documents, it has a page 1 on it, and
5 it is the first of five pages for that particular date.
6 A. First of what?
7
8 Q. It is 7th December 1992 at the top right-hand corner.
9
10 MR. JUSTICE BELL: It is about halfway through in fact, maybe a
11 third. They are in chronological order, Mr. Brown,
12 I think. Keep going until you come to 7th December 1992.
13 A. Yes.
14
15 MR. MORRIS: You have that?
16 A. Yes.
17
18 Q. If you look on page 1 it has two-thirds of the way down:
19 "Unless health and safety is talked about in cost terms
20 with hard figures, top management will not be
21 interested." Why, in your experience, would top
22 management not be interested unless health and safety is
23 talked about in cost terms with hard figures?
24 A. I have no idea.
25
26 Q. If you turn over the page, under 4.2 "Accident Statistics",
27 below the bit that has been blanked out above it, the first
28 point: "The Total has gone up by 20 per cent. Floor
29 managers and dining area hosts still have the highest
30 incidence of slips and falls." Do you not think, bearing
31 in mind that McDonald's position at that time in 1982 was
32 that dining area hosts as well as floor managers still have
33 the highest incidence of slips and falls, that as they are
34 working in the dining area most of the time that the dining
35 area should also be fitted with slip resistant tiles as
36 well as the other areas?
37 A. It says here: "Floor managers and dining area hosts
38 still have the highest incidence of slips and falls". It
39 does not say where they are having the slips and falls.
40
41 Q. If it is a dining area host?
42 A. Well, it could be in the kitchen while the person is in
43 the kitchen area, or it could be while they are having
44 their meals in the crew room.
45
46 Q. If a conclusion could be drawn -----
47
48 MR. RAMPTON: My Lord, I have some doubt as to whether this is
49 the right witness to cross-examine about this topic.
50
51 MR. JUSTICE BELL: Yes.
52
53 MR. MORRIS: Unfortunately -----
54
55 MR. RAMPTON: It is pure speculation. It is not speculation; it
56 is comment, in effect. Your Lordship may well conclude
57 that the likeliest place for the dining area person to
58 spend most of their working day is in the dining area, I do
59 not know.
60
