Day 207 - 23 Jan 96 - Page 55


     
     1
     2   Q.   But you would have to take part in one if you were in the
     3        store?
     4        A.  If I was in the store and one was performed, I would
     5        take part in it.
     6
     7   Q.   Then if you turn to page 205 -----
     8
     9   MR. JUSTICE BELL:  Is Bath all on one floor, or does it have a
    10        lower floor or an upper floor?
    11        A.  There is, basically, the restaurant ground level as you
    12        walk in; there is the counter area; then there is a top
    13        dining area; and, as you walk up the back stairs, there is
    14        a landing that takes you into the top ---
    15
    16   Q.   So there is an upstairs?
    17        A.  -- top lobby, and then you go up into the crew room
    18        again, and there is a sort of mini-level where the trash
    19        room and the back door entrance is, in between the lower
    20        restaurant ground and the back door -- sort of split
    21        levels.
    22
    23   MS. STEEL:  If you look at page 205, under "Health and
    24        Safety": "No knowledge of COSHH.  Not enough plasters and
    25        of the right shape.  All of it is locked in the office.
    26        Crew do not feel Managers take it seriously."  Do you
    27        remember that complaint?
    28        A.  No.
    29
    30   Q.   Is that right that the Accident Book and First Aid kit are
    31        locked in the office?
    32        A.  The First Aid equipment and the Accident Book are kept
    33        downstairs in the office in the righthand cupboard, and the
    34        additional First Aid plasters, et cetera, are kept upstairs
    35        in the office.
    36
    37   Q.   The office downstairs is, what, generally kept locked?
    38        A.  No, it is an open plan office; you can just walk -- any
    39        member of staff can just walk straight in.  It actually
    40        connects to the kitchen area.
    41
    42   Q.   So, is the upstairs office kept locked, where the plasters
    43        are kept?
    44        A.  The plasters are kept downstairs and there is an
    45        additional stock of plasters kept upstairs.
    46
    47   Q.   But where it is referred to as "locked in the office", do
    48        you remember a problem?
    49        A.  No.
    50 
    51   Q.   Any complaints of crew not being able to get plasters or 
    52        the Accident Book? 
    53        A.  No.
    54
    55   MR. JUSTICE BELL:  Well, in one of the audits, they are marked
    56        down because they have run out of plasters.
    57
    58   MR. MORRIS:  On page 178, it says "no plasters".
    59
    60   MR. JUSTICE BELL:  But you do not remember any discussion about

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