Day 207 - 23 Jan 96 - Page 37
1
2 THE WITNESS: Section 5.
3
4 MS. STEEL: OK. "...for August 1993, May 1994 and August
5 1994. Without knowing the precise volume of business in
6 the restaurant for each of the hours shown on the sheets
7 I cannot say for certain that the staffing levels were
8 always exactly what was needed to provide the required
9 standards of service."
10
11 So, is that a recognition there that sometimes the stores
12 were understaffed?
13 A. From looking at the crew in store each hour, that would
14 give you a report of the number of hourly paid staff
15 working up to that hour, provided they did not -- say in
16 the period of 4/8/93, up till nine o'clock, it says nine
17 people; if someone took a break before that period, it is a
18 minimum staffing level. Basically, if they took a break
19 before one minute to nine, they would not be included in
20 that. From that, you can take a look through and arrive at
21 an opinion from -- well, it shows you the staffing levels.
22 As you go through the printouts which show hour by hour the
23 number of staff working, in my opinion, it was not --
24 during this period it was not understaffed.
25
26 Q. Are you saying it was never understaffed?
27 A. I am saying in this period -- there are occasions when,
28 perhaps due to illness or something, then you could run
29 short of staff and have to call staff in, et cetera. But
30 during this period it was not deliberately understaffed.
31
32 Q. You are aware, presumably, of complaints in the rap
33 sessions about understaffing from time to time?
34 A. Within the rap session, it does say -- I believe there
35 are comments about understaffing.
36
37 Q. Was any notice taken of those complaints?
38 A. In doing the schedule, you are always trying to
39 schedule the correct amount of staff that the store needs;
40 so you would take notice of those comments. But you would
41 not wait for a rap session if you felt there was a need for
42 staff.
43
44 Q. If a complaint was made by a crew at a rap session about
45 short staffing -- well, complaints were made. As a result
46 of any of those complaints, were the numbers of people
47 working on given shifts increased?
48 A. As I said, in my opinion, the restaurant was not
49 understaffed; and I would not use the rap session as a
50 guide to the number of -- a rap session report as a guide
51 to what I felt the restaurant needed. I would update it
52 more frequently than that. So, if I felt that there were
53 more staff needed or the staff was adequate, I would say
54 the numbers that I felt could run the restaurant properly.
55
56 Q. Sorry, did you say you would or you would not use the rap
57 session as a guide?
58 A. Would not.
59
60 MR. JUSTICE BELL: He said that he would not; he would update
