Day 128 - 24 May 95 - Page 63
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2 MS. STEEL: The other thing is a copy of the health and safety
3 audit form and the personnel audit which had health and
4 safety matters on it, according to Mrs. Barnes. I have a
5 feeling though there are some others.
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7 MR. JUSTICE BELL: Pick those up in the morning, if you want.
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9 MS. STEEL: The High Levels magazine and the Crew magazine, that
10 is something that has been specifically referred to by
11 Mrs. Barnes as somewhere where they were getting their
12 health concerns about health and safety across to crew
13 members and management, in order for them to take action.
14 On those grounds I feel that they ought to be disclosed.
15 They are being relied on by the Plaintiffs.
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17 MR. JUSTICE BELL: You do not want the lot. What you are
18 enquiring about is, you say Mrs. Barnes has said that,
19 surely what you are enquiring about is whether there is any
20 particular copy which she has in mind. At the moment I am
21 not too much in favour of that; the reason being that we
22 have quite a lot of documentation which might help me, one
23 way or the other, as to whether McDonald's was getting the
24 question of health and safety across.
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26 Although Mr. Rampton has an argument, which may well have
27 merit, about the relevance of matters which have happened
28 since 1990, I have to keep reminding myself that the
29 leaflet was published in 1989/90, according to the
30 allegation made against you and Mr. Morris. At the moment
31 what I am minded to say is I think that someone should look
32 at a copy of the health and safety audit form and the
33 personnel audit forms as well.
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35 In fact, I really do not see why copies of those should not
36 be shown to Ms. Steel and Mr. Morris. I do not know how
37 long they are.
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39 MR. RAMPTON: My Lord, we will look at all these documents. We
40 will look at the full report of which these three sheets
41 and 57M -----
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43 MR. JUSTICE BELL: I am not terribly interested in the magazines
44 at the moment because I have no way of knowing, even if
45 they do appear in the magazines, how many crew members
46 bother to read them.
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48 MR. RAMPTON: My Lord, I hope I have understood your Lordship's
49 thinking. If there is any relevance in it (and I have to
50 say that I have to reserve my position about that), what
51 your Lordship would be interested in would be what I might
52 call "hard data" about the safety of the operation for the
53 people who run it, and about, as it were, the Company's
54 internal concerns, to use it in its modern sense, and
55 careful interests of their own employees, which your
56 Lordship is not going to find except in the form of, sort
57 of, public statement in the Company magazines.
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59 MS. STEEL: If I could make a suggestion which is that,
60 obviously, it might take some time for those to be
