Day 127 - 23 May 95 - Page 22


     
     1        argument to them but they will follow the Company line.
     2
     3   Q.   Then please turn over to 718.  We observe as we go through
     4        these, Mrs. Barnes, a number of them come from Frank Frost
     5        who, as you have told us, is in the Northern region.  The
     6        Hopkins accident happened in the Northern region, did it
     7        not?
     8        A.  It did, yes.
     9
    10   Q.   This one which has a slightly later date appears to be more
    11        or less identical, does it not, but it goes to different
    12        people in Yorkshire and the North East, do you see that?
    13        Anyway perhaps ---
    14        A.  Yes.
    15
    16   Q.   -- it does not matter.  I would like you to look with
    17        particular care, please, at 719.  It is said to come from
    18        you.  Would you, please, turn over to 720 and tell us
    19        whether that is, indeed, your signature at the bottom of
    20        the page?
    21        A.  It is my signature, yes.
    22
    23   Q.   There is Richard Rowley, the Equipment Manager, on the
    24        right-hand side, correct?
    25        A.  That is correct, yes.
    26
    27   Q.   This, it appears, goes to all store managers; is that
    28        right?
    29        A.  It does, yes.
    30
    31   Q.   But those are Company store managers?
    32        A.  Yes, it is also copied to franchisees, the licensees in
    33        there too.
    34
    35   Q.   It is, is it?  Yes, I see.  I notice that it says:  "Field
    36        Consultants" in the third line at the end, do you see that?
    37        A.  I do.
    38
    39   Q.   Are they the people that deal with the licensees?
    40        A.  They are Company employees that liaise with the
    41        franchisees, and part of their role is to make sure the
    42        franchisees are complying with Company systems and meeting
    43        standards.
    44
    45   Q.   Its date is 14th May 1991.  I remind you that the Hopkins
    46        accident took place on 12th October 1992.  It is from you
    47        and its subject is "Electricity at Work Regulations".  Then
    48        there is a box which says:  "Danger".  Beneath that:
    49         "REMEMBER, ELECTRICITY KILLS" in capital letters.  This
    50        may be obvious, but forgive me:  What is the purpose of 
    51        inserting that box in this memorandum? 
    52        A.  Well, Richard and I both felt that it needed to be a 
    53        joint memo to give it some weight, but that we needed to go
    54        even further to get the message over to our Operations
    55        people, that electricity did have the potential to kill
    56        somebody.  Our Company then had been in place 15 years, and
    57        it was very easy for somebody to turn around and say:
    58         "Yes, but, you know, nobody has ever been
    59        seriously injured by electricity at McDonald's", and that
    60        is just really an example of how we were applying risk

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