Day 086 - 09 Feb 95 - Page 20


     
     1   Q.   So if there was an accident anywhere in the country that
     2        was serious Jill Barnes would investigate?
     3        A.  It would go to Jill Barnes as the health and safety
     4        officer.  In 1992 we had 150 less restaurants than we do at
     5        the moment, so as a function of our expansion we have
     6        expanded the people that deal with health and safety.  She
     7        would not be able to do all of them.  She would -- this
     8        really is for her to tell you what she did three years ago.
     9
    10   Q.   We are talking about systems here and you are in charge of
    11        the health and safety systems?
    12        A.  I am in charge in 1995, in 1992 I was not.
    13
    14   Q.   Yes, but you were in an important position in 1992, were
    15        you not?
    16        A.  1992, I was, February, I was an Operations Manager.
    17        Reported incidents would have been reported to Jill Barnes.
    18
    19   Q.   He says in this letter:  "I have not been notified of these
    20        accidents".  He is Frank Frost, presumably, from that
    21        northern region.  So, does the system there seem to be that
    22        these severe shocks "several recent instances in the
    23        northern region and I have not been notified", the system
    24        there was that he should be notified?
    25        A.  No.
    26
    27   Q.   Are you saying he is wrong?
    28
    29   MR. JUSTICE BELL:  Let us just get it straight.  You can be
    30        notified in various ways.  You can be the primarily
    31        notifiable person or it can go to someone else, you would
    32        suggest Jill Barnes.  Then we have to look at who should be
    33        notified by her department?
    34        A.  That is correct, I do not think -----
    35
    36   Q.   Can you say what the position was in 1992?
    37        A.  In the northern region, I do not know what their
    38        administration system was for reporting of accidents.
    39        I know at that time in the company, from myself in the
    40        Midlands, it was to Jill Barnes and then that was the
    41        important notification that we would make in her position
    42        as having overall responsibility for the administration of
    43        health and safety, that she would then inform relevant
    44        parties.
    45
    46   Q.   Do you know who the people considered to be relevant were,
    47        only say if you do know?
    48        A.  I do not know in the northern region.  I have never
    49        worked in that region.
    50 
    51   MR. JUSTICE BELL:  We understand she is going to be a witness. 
    52        A.  Frank Frost was an Equipment Manager, I believe, in the 
    53        northern region at that time.
    54
    55   Q.   So would you expect him to be informed?
    56        A.  If the accident was alleged to equipment, he may well
    57        be, but it would have been Jill's judgment.
    58
    59   Q.   It would come via her?
    60        A.  It would come via her.

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