Day 169 - 04 Oct 95 - Page 18


     
     1        A.  Yes.
     2
     3   Q.   So when you have got a customer complaining about products
     4        being undercooked, you made the decision about whether you
     5        thought it was undercooked?
     6        A.  For a start, no-one has ever come to me and given me a
     7        meat pattie and said:  "That is undercooked".
     8
     9   Q.   You do not know what the procedure is?
    10        A.  I do know what the procedure is because I am taught
    11        what the procedure is and I am taught the procedure to
    12        follow.  What I am saying is I have never had to follow
    13        that procedure because the incident has never occurred.
    14
    15   Q.   So you are putting down the Company's theory on what is
    16        supposed to happen?
    17        A.  As far as I am aware, as far as I have been taught by
    18        the successive levels of operations management above me,
    19        that is the procedure I am to follow should I receive a
    20        problem with a meat bearing sandwich, yes.
    21
    22   Q.   You do not know whether or not that is the practice on the
    23        ground in the store?
    24        A.  I know that that is the practice on the ground in my
    25        store, yes, because that is what we are all taught.
    26
    27   Q.   Have you witnessed people doing?
    28        A.  No, I have not witnessed people doing it.  I cannot say
    29        whether every Manager would do exactly that procedure, but
    30        that is what they are taught to do, and if they are doing
    31        their job properly, that is what they should do.
    32
    33   Q.   Have you seen any incident report forms of undercooked meat
    34        products?
    35        A.  Not that I can recall, no.
    36
    37   Q.   What happened to the ones that did take place?
    38        A.  Sorry?
    39
    40   Q.   What happened to the ones that did take place?
    41        A.  I have told you that I have never received a problem --
    42        a complaint from a customer where they have come to me and
    43        they have said:  "Look, my chicken pattie is raw; my Big
    44        Mac is raw".  If that did happen in the store, I am unaware
    45        of it.  No-one has ever come to me and complained about it.
    46        The incident report forms you refer to are the -- I have
    47        told you there were three instances of alleged food
    48        poisoning in the year, the final engine that Mike Logan
    49        left.  Those instances of food poisoning are where people
    50        have gone home, complained at a later date that they have 
    51        got food poisoning.  They have never actually brought us a 
    52        product and said:  "This product is uncooked". 
    53
    54   Q.   Right.  You have not seen any incident report forms about
    55        undercooked meat products?
    56        A.  As far as -- I have never filled in an incident report
    57        form about an undercooked meat product, as far as I can
    58        recall, and I cannot recall seeing any, no.
    59
    60   Q.   You said:  "The vast majority of complaints about

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