Day 086 - 09 Feb 95 - Page 29
1 MR. MORRIS: Can I ask you just one outstanding question, if
2 I could just butt in there. All fat filtering machines now
3 do have residual current devices, yes?
4 A. Yes, I believe all the equipment that we have, portable
5 equipment has it -- no, all the equipment has it.
6
7 Q. All equipment has it?
8 A. All equipment has got RCD.
9
10 Q. That device costs about £25, something like that?
11 A. I do not know the cost. I would not dispute that.
12
13 Q. I will not refer to it but it was in volume XIII, tab 52,
14 page 780. It was a memo the day after the accident. It
15 says it costs £20 at that time. Thank you.
16
17 MS. STEEL: Can you turn to page 521, please?
18
19 MR. JUSTICE BELL: That is not £20 for every machine? That is
20 just the thing I have on my electric lawn mower and I stick
21 in the socket and then the plug into that?
22 A. It is similar to that, similar to that on each piece of
23 equipment. 521?
24
25 MS. STEEL: Yes. It is upside-down for some reason.
26 A. I was going to say on mine it is upside down as well.
27
28 Q. You were talking about travel paths yesterday, is this the
29 typical travel path?
30 A. Yes, each stores will be different because of the
31 layout. That is just a schematic generalisation on a
32 travel path.
33
34 Q. There is nothing in there about health and safety?
35 A. Travel path is where you walk around, and I will check
36 it through. Crew positioning could be construed as health
37 and safety as who is in charge.
38
39 Q. How could -----
40 A. If they are positioned safely or not safely, that there
41 is someone in charge of the area that they are being
42 supervised; checking the pavements, again that could be
43 health and safety, to make share sure that they are in safe
44 condition; again the backyard, if it is clean and
45 organised, if it is, then that would be safe; floor control
46 in itself, that is one of the major contributors to health
47 and safety that we are looking that people are working
48 effectively and safely; again lobby, that the floor is
49 clean and dry, that is checking, you know, on a health and
50 safety matter.
51
52 Q. That would be something that would affect the safety of the
53 customers?
54 A. Yes, when you are out in the dining area, that is
55 correct; kitchen/back room, again cleanliness, the fact
56 that it is clean, organised -- I have got a bit missing in
57 the punching of the paper.
58
59 MR. JUSTICE BELL: "Sinks"?
60 A. Yes, sinks, again the freezer, the walk-in
