Day 084 - 07 Feb 95 - Page 49


     
     1        A.  If you mean overall what are my responsibilities, I do
     2        not know overall.
     3
     4   Q.   She is answerable to you, is she not, Jill Barnes?
     5        A.  Yes, and I am answerable to someone else.
     6
     7   Q.   I suppose everyone is answerable to someone else until you
     8        get to the President, but you are here to give evidence on
     9        the company's responsibility for employee accidents, are
    10        you not?  That is your responsibility?
    11        A.  Health and safety is my responsibility, yes, and that
    12        employee accidents come underneath that.
    13
    14   Q.   Does it not concern you that your company does not have any
    15        accident statistics apart from their legal obligation?
    16        A.  We do have accident statistics other than our legal
    17        obligation.  They are in the blue book facts.
    18
    19   Q.   They are not statistics though, are they?  They are
    20        informal notes.  That is also the law, is it not, to have a
    21        blue book in store, an injury reporting book?
    22        A.  I think you need to do that, yes.
    23
    24   Q.   It is the law, is it?
    25        A.  I am not an expert but I believe it is the law.
    26
    27   Q.   So, apart from your legal obligations, does it not concern
    28        you that a company which prides itself so much according to
    29        your statement or Mr. Wignall's statement on its commitment
    30        to workers' safety, does not have any comprehensive
    31        overview of statistics and analysis of them?
    32        A.  I think, as I mentioned at the beginning, when you
    33        manage safety within the company you have to prioritise
    34        areas of importance.  Obviously, most important to us are
    35        the accidents.  We have statistics which record all those
    36        down.  I think it is a sensible management of the health
    37        and safety policy to prioritise those areas. Although we
    38        are concerned about a crew member who may have a minor cut
    39        on his finger, stub his toe, bruise his knee, I would
    40        prefer to have people within the company working towards
    41        solving or preventing the more serious accidents. I think
    42        that is common sense.
    43
    44   Q.   So if they only spend two days in hospital and it does not
    45        result in a RIDDOR obligation under the law, then that does
    46        not have priority -----
    47
    48   MR. JUSTICE BELL:  Hold on a moment.  The "in hospital", what is
    49        that related to?  The days were days off work.
    50 
    51   MR. MORRIS:  Mr. Atherton said, it was not clear, he said at one 
    52        time it was three days in hospital. 
    53        A.  It was three days off work.  I may well have referred
    54        to three days in hospital.
    55
    56   MR. RAMPTON:  My Lord, maybe it is better not to speculate about
    57        an easily verifiable matter of fact.  There is a McDonald's
    58        document, no doubt the Defendants will say it is a pack of
    59        lies, even so there is a McDonald's document at page 759
    60        tab 52 of pink 13 which sets out in terms what are the

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