Day 084 - 07 Feb 95 - Page 38
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2 MR. RAMPTON: Yes.
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4 MR. JUSTICE BELL: I will move that across when we come to it.
5 Thank you.
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7 MS. STEEL: The older observation check lists are in document
8 117 of the Defendants' first list of documents.
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10 MR. MORRIS: Where we are putting this? Is it 57-O?
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12 MR. JUSTICE BELL: I am going to put them at the back of this
13 bundle with the ones which Mrs. Brinley-Codd has just
14 handed up. When you come to observation chick list
15 I suggest we pause for a couple of minutes and get them all
16 together in one place from the various bundles. Are you
17 going straight to that now.
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19 MS. STEEL: No, I am not.
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21 MR. JUSTICE BELL: Perhaps we could bear that in mind. If you
22 are anxious to make it clear that it was one of your
23 documents, the old one, when we do that remind me to write
24 on top of it "Defendants' document".
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26 Cross-Examined by the Defendants.
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28 MS. STEEL: When you were giving evidence about the number of
29 accidents in relation to the number of employees, you said
30 that you have 32,000 employees working for us 364 days of
31 the year and 16 hours per day. You were not trying to
32 suggest that all 32,000 employees were working those hours,
33 were you?
34 A. Indeed I was not, no.
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36 Q. Most of your employees are part-time?
37 A. The majority are, yes. The point was that the
38 statistics, you had to consider the amount of time people
39 working in the restaurants to put them into some sort of
40 perspective.
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42 MR. JUSTICE BELL: Is the day missing Christmas Day or some
43 other day?
44 A. Christmas Day.
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46 MS. STEEL: I think we may have had this before, but I am not
47 sure. Could you say how many hours the average employee
48 works per week?
49 A. I am afraid I would not know that.
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51 Q. You do not know?
52 A. No.
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54 Q. What are the most frequent accidents that occur in stores?
55 A. Slips, trips and falls.
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57 Q. What about burns?
58 A. I do not think they occur as frequently -- as regards
59 reportable accidents it is slips, trips and falls.
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