Day 136 - 16 Jun 95 - Page 18


     
     1        do you have a copy of the map?
     2        A.  Yes, I have.
     3
     4   Q.   Sorry, the plan -- I keep calling it a "map" -- could you
     5        just summarise what the designated areas are?  We are
     6        talking about the kitchen area, not the front counter but
     7        behind that?
     8        A.  OK.  On this particular drawing we have a centre line
     9        that is running across from left to right.  Now, the first
    10        piece of equipment that is to the left just behind the
    11        counter, that is what we call a centre island.  We have
    12        non-slip floor tiles shown there.
    13
    14   Q.   On the back of that?
    15        A.  On the back of that.
    16
    17   Q.   Yes.  Then the bit ------
    18        A.  We also have, if I can just carry on to explain the
    19        question that you have asked me, all the areas that are
    20        shown as shaded, we have non-slip floor tiles in front of
    21        the four griddle islands -- that is that centre rectangular
    22        block which is approximately an inch and a half by three
    23        and a half inches -- that is where the four griddles were.
    24
    25   Q.   Sorry, is this the one just beneath the Manager's area on
    26        the plan?
    27        A.  No, that is a preparation area, so where the crew
    28        members are preparing the buns and putting in the
    29        ingredients.  We have the non-slip area in front of that
    30        piece of equipment.  We also have the non-slip material in
    31        front of the fry station which is the one just to the right
    32        of it going back towards the counter.
    33
    34   MR. JUSTICE BELL:  Look, if I hold mine up, I would like you
    35        just to say, because I think I can see where the shading is
    36         -----
    37        A.  All those -- sorry, all these shaded areas basically
    38        are in front of equipment where we feel it is necessary to
    39        have it.
    40
    41   MR. JUSTICE BELL:  That is precisely what I was going to ask
    42        you.  Just pause a moment.  I have put a "1" there on that
    43        piece of apparatus because I can see there is non-slip
    44        beneath it.  What is at 1?
    45        A.  That is a fry station.
    46
    47   Q.   Right.  I have put a "2" on that island because I can see
    48        there is non-slip to the right of it?
    49        A.  That is the centre island.
    50 
    51   Q.   What is at 2? 
    52        A.  It is where the products once they are cooked and 
    53        wrapped are kept.
    54
    55   Q.   I have put a "3" on a shape which is much the same as 1 but
    56        at the bottom of the plan.
    57        A.  That is also a fry station.
    58
    59   Q.   I have put a "4" on the block moving to the larger spaces
    60        to the right because I can see that has non-slip on either

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