Day 132 - 07 Jun 95 - Page 35


     
     1        is an expert on safety?
     2        A.  Staggeringly naive?  Why should it be staggeringly
     3        naive?  Can I just point out that legal advice is readily
     4        available, that solicitors advertise on all the national
     5        newspapers saying:  "If you have had an accident, come to
     6        us".  Why should someone not take action if they feel
     7        aggrieved?  I do not think that is staggeringly naive.
     8        I think it is staggeringly naive to put it.
     9
    10   MR. JUSTICE BELL:  You need bother with that.  I know that there
    11        are figures that show that about three per cent of people
    12        who might have good claims for damages for negligence take
    13        advice, let alone take action; the other 97 per cent do
    14        nothing.
    15
    16   MR. MORRIS:  If we go over the page in the middle of the page,
    17        point 9?
    18        A.  Sorry, page?
    19
    20   Q.   I am sorry, page 14, Peter Sutcliffe describes how
    21        "Pressure was on to unload as fast as possible" -- sorry,
    22        that is not a quote from his statement.  "Peter Sutcliffe
    23        describes how the pressure was on to unload as fast as
    24        possible.  Indeed, the sooner goods are stored the better"?
    25        A.  Yes.
    26
    27   Q.   If there is pressure to unload as fast as possible,
    28        I presume he is implying a safety concern ---
    29        A.  Yes.
    30
    31   Q.   -- with that, would that concern you?
    32        A.  It could do, yes, it depends on the load and what speed
    33        and how that pressure was applied.
    34
    35   Q.   Page 15, under point 13, you quoted the statement of
    36        Nicholas McGill to say:  "The store did not follow the
    37        training procedures it was supposed to"?
    38        A.  Yes.
    39
    40   Q.   Your response was:  "I find it hard to believe that the
    41        training room was never used"?
    42        A.  Yes, that is one of the things that he said in his
    43        statement, yes.
    44
    45   Q.   Yes.  If the training procedures are not followed that are
    46        supposed to be, would that concern you?
    47        A.  Yes, of course.
    48
    49   Q.   In the next paragraph you said you found it "difficult to
    50        accept" that the heating in the crew room, I cannot 
    51        remember the actual statement, but it think it was --- 
    52        A.  Had been deliberately isolated. 
    53
    54   Q.   -- too low or something?
    55        A.  Oh, yes, I think, without going back to the statement,
    56        I think the comment was that the manager had deliberately
    57        withdrawn all the heating from the crew room and that it
    58        was permanently freezing in there.
    59
    60   Q.   That is a possibility, is it not?  Management want to

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