Day 128 - 24 May 95 - Page 20
1 then. Normally, we would meet with the Manager before the
2 Environmental Health Officer arrived, so we could go
3 through all the details with them beforehand. So
4 I certainly would have expected Mark to go through it all
5 with the Manager.
6
7 Q. You do not know whether any supervisory staff got a warning
8 about not making, they should not make crew members work in
9 ways that was a danger to their safety?
10 A. I do not know whether they had a formal warning, no.
11 I would have expected the Restaurant Manager to have taken
12 it up with his management team.
13
14 Q. The second letter from Mark Hathaway on 2nd August 1993, he
15 says about a second clamshell grill unit being supplied on
16 5th August. That would have been one and the same, would
17 it?
18 A. Well, what we had in place in quite a lot of stores at
19 that time was one full clamshell grill for the regular meat
20 patties, and a mini clamshell for the quarter pounders.
21 This would indicate they were having a second full
22 clamshell. It does not make it clear, really, from
23 Mr. Nelson's letter which of the two grills are causing the
24 problem.
25
26 Q. So it was supposition on your part that it referred to a
27 quarter pounder grill?
28 A. He does say "mini clamshell", which is our terminology
29 for the quarter grill, which I am basing that on.
30
31 Q. Do you think it is acceptable that the Company took the
32 better part of three months to do something about this
33 problem of employees getting burnt?
34 A. It depends really the time line that occurred, and we
35 cannot really tell from looking at this, but it might have
36 been difficult for Mark to meet up with Mr. Nelson
37 straightaway. It then would have needed time to arrange
38 for the grill to be ordered.
39
40 Normally, I would expect us to reply, these days in
41 writing, within two weeks to an Environmental Health
42 Officer, unless a meeting was taking place, and then within
43 a few working days after the meeting to have a letter put
44 together, but I really cannot remember the specifics of
45 this particular contact.
46
47 Q. Mr. Nelson, mentions his investigations in his letter of
48 19th May. Presumably, he would have been to the store to
49 make those investigations?
50 A. I would have thought he would, yes.
51
52 Q. It sounds like he has visited the store from the letter, so
53 the store management would have been aware of the problem
54 at that time?
55 A. They would, yes.
56
57 Q. They could have done something about it much sooner, could
58 they not? They could have ordered another clamshell grill
59 to reduce the pressure to the speed at which cleaning had
60 to be done, for example?
