Day 303 - 19 Nov 96 - Page 12


     
     1        it up and other companies would reduce it, but overall the
     2        sector is identified as reporting something like ten to 15
     3        per cent.
     4
     5   MR. JUSTICE BELL:  Yes.
     6
     7   MR. MORRIS:  If a thousand industrial injuries from that sector
     8        are reported we can multiply that thousand by seven to ten
     9        to bring it up to 100 per cent of what it would be if they
    10        were all reported.  So then that would mean that seven to
    11        10,000, approximately, actual injuries, reportable
    12        injuries, occur in that sector, of which -- so that is the
    13        figure, seven to 10,000.  Let us assume McDonald's report
    14        600 out of that thousand because they are the majority, if
    15        it was less than that, they would probably say about half
    16        it could be more than that, but we are giving them the
    17        benefit of the doubt by calling it 600, if McDonald's
    18        reporting rate is something like 50 per cent.
    19
    20   MR. JUSTICE BELL:  Where have you got the 50 per cent?
    21
    22   MR. MORRIS:  It is a completely arbitrary figure that this is.
    23        Do not forget for 1989 we are comparing it with...  We do
    24        not know.  Jill Barns plucked a figure and said that she
    25        thought the reporting rate in 1992, I think, was 80 per
    26        cent, which is completely her figure, so it is bound to be
    27        something less than that if that is McDonald's own figure.
    28
    29        Secondly, we can look at the reporting rate of injuries in
    30        accident books and the evidence of our own witnesses about
    31        how seriously or not seriously McDonald's management do
    32        take injuries, and I think that 50 per cent is a charitable
    33        figure in McDonald's favour, that they are something like
    34        three to five times the reporting rate of the services
    35        sector.  So I am giving them a healthy three to five times
    36        the reporting rate of the services sector as a whole and
    37        saying that the report could be something like 50 per cent,
    38        in which case if they report 600 the actual injuries would
    39        be 1,200, out of that seven to 10,000, which is 12 to 17
    40        per cent of all accidents -----
    41
    42   MR. JUSTICE BELL:  Well....
    43
    44   MR. MORRIS:  Will be the responsibility of McDonald's.  These
    45        are reportable accidents and -----
    46
    47   MR. JUSTICE BELL:  I just do not know the basis upon which it is
    48        suggested that McDonald's report the majority of the
    49        accidents.  It seems to me that once you say the sector
    50        only reports ten or 15 per cent it is another way of saying
    51        in fact you do not know how many there are as it is such a
    52        small percentage.  I can see if you say 80 per cent of
    53        accidents are reported you must have a pretty good idea to
    54        know what 100 per cent is in order to get the 80, but once
    55        you are down to saying they only report ten or 15 per cent
    56        you are saying hardly any accidents are reported.
    57
    58   MR. MORRIS:  It was Mr. Rampton's case to Mr. Pearson that it
    59        was 16.5 per cent was the actual reportable figure for the
    60        services sector.

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