Day 132 - 07 Jun 95 - Page 32


     
     1
     2   Q.   So you are not really responding, are you, to the criticism
     3        which is that expense can mean that things are not fixed?
     4        A.  I think I am responding to the criticism.  As far as
     5        I am concerned, the culture in McDonald's is not to say:
     6         "We are not spending on health and safety; we are trying
     7        to save money".  That is not the culture at McDonald's and
     8        I am making that point.
     9
    10   Q.   In the next paragraph, paragraph 4 -- just going back to
    11        that previous one, you would be concerned, though, if
    12        nothing was done to fix something because of expense?
    13        A.  Of course I would be concerned, yes.
    14
    15   Q.   You did not express that concern though in your statement?
    16        A.  That is because I said I do not believe that to be the
    17        condition.
    18
    19   Q.   No, you said that money would not be denied.  You did not
    20        say that you would be concerned if that was the case.
    21
    22   MR. JUSTICE BELL:  You do not need to include everything, do
    23        you?  Rightly or wrongly, he was asked to deal with
    24        particular statements.  It seems a bit unfair to put to
    25        Mr. Purslow that he did not mention something which might
    26        be fairly obvious anyway.
    27
    28   MR. MORRIS:  Paragraph 5 at the bottom of that page, comment is
    29        made about a girl slipping on a wet floor and burning her
    30        arm on the grill.  You do not know, you say, why the
    31        statement goes on to say that she was sent to hospital
    32        "with some reluctancy"?
    33        A.  Yes.
    34
    35   Q.   Would you be concerned if there was some reluctance to call
    36        an ambulance or send them to hospital?
    37        A.  Yes, indeed -- if, in actual fact, it was necessary,
    38        I have to say.
    39
    40   Q.   In grey areas of uncertainty, is it better to err on the
    41        side of caution and safety of the employee?
    42        A.  What grey areas are we talking about?
    43
    44   Q.   If there is a grey area of not being sure whether an
    45        ambulance should be called or -----
    46
    47   MR. JUSTICE BELL:  You had better separate the ambulance because
    48        it is not in the public interest to call ambulances unless
    49        they are absolutely necessary because someone may be in far
    50        more dire straits than you are at the same time.  But if 
    51        you did not know whether an injury ought to receive medical 
    52        attention or not, the only safe thing to do would be for 
    53        someone to get in their car and take the person to the
    54        nearest Accident and Emergency Department?
    55        A.  Absolutely, my Lord, and one would err on the side of
    56        caution in that sense but, as you rightly say, you would
    57        not necessarily call an ambulance.
    58
    59   MR. MORRIS:  On page 13 at the top:  "It is further stated that
    60        for six Saturdays on the trot the toaster was giving people

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