Day 247 - 10 May 96 - Page 28


     
     1   MR. JUSTICE BELL: Where is it in fact?  Have we not found it?
     2
     3   MR. RAMPTON:  I cannot find it, my Lord, nor can
     4        Mrs. Brinley-Codd.  I really do not know.
     5
     6   MR. JUSTICE BELL:  Let us see where we get to (handed) Thank
     7        you.
     8
     9   MR. MORRIS:  Shall I hand up the whole document?
    10
    11   MR. JUSTICE BELL:  No.  Ask your questions first of all and then
    12        if there is any query about it, you may have to.
    13
    14   MR. MORRIS:  The first page, Mr. Preston, can you see that?
    15        A.  Yes.
    16
    17   Q.   Does it say, "Ross Park:  Quality Safety Audit" on it?
    18        A.  It does.
    19
    20   Q.   Does it say: # "designed to measure progress versus
    21        'successful health and safety management', i.e. HSE
    22        guidelines"?
    23        A.  It does.
    24
    25   Q.   We are talking about official HSE terminology here, yes?
    26        A.  I do not official or unofficial.  I know what it says
    27        on paper.
    28
    29   Q.   OK.  It says "not legal requirement but part of audit
    30        measures compliance with latest legislation".  Then it has
    31        five sections and it has various weighting to do with
    32        it: "The weighted score gives health and safety performance
    33        rating"; yes?
    34        A.  Yes, that is what it says.
    35
    36   Q.   Then on the next page it has:  "Comparative QSA scores" and
    37        for 1991/92, which has "HSE", so presumably this is the
    38        time of the HSE Report which was into McDonald's health and
    39        safety activities because there was no measurement before
    40        the HSE report was there, so this would be an HSE rate?
    41        This is what I am assuming?
    42        A.  I am not familiar with all the terms you are using.
    43
    44   Q.   In 1991/92 the percentage scores were:  Policy, 38 per
    45        cent; organisation 14 per cent -- this is out of 100 --
    46        plan and implementation, 17 per cent; measuring, 0 per
    47        cent; audit review, 0 per cent, and the total HSPR, which
    48        on the previous page was health and safety performance
    49        rating, was 13.4 per cent in 1991/92.  Then there was an
    50        improvement over the next couple of years to June 1994 when 
    51        the HSPR was 89 per cent. 
    52 
    53        So, would you accept that in 1991/92, the first time that
    54        safety was measured at McDonald's in the kind of formal
    55        way, you had an absolutely appalling  ----
    56
    57   MR. JUSTICE BELL: I do not think this helps one bit.  We have
    58        had days and days of evidence where we went through the
    59        report in question, we had what expert witnesses thought
    60        about it and everything else.  That is an argument you can

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