Day 086 - 09 Feb 95 - Page 14
1 health and safety expert a handle such as that could have
2 prevented someone's death if it had been there, would that
3 concern you?
4 A. If a health and safety professional said that, it would
5 obviously concern me, if that was his opinion.
6
7 Q. If it had been missing for months, would that have
8 concerned you even more?
9 A. No, I do not think so.
10
11 Q. But would it concern you that if a piece of important
12 equipment, whether a handle or whatever, which is needed
13 has not been fixed for months, would that indicate to you a
14 breakdown of some kind of management responsibility in
15 the -----
16
17 MR. JUSTICE BELL: Just sloppiness -- would it indicate
18 sloppiness to you?
19 A. On its own, no.
20
21 MR. MORRIS: Are you saying that if a piece of electrical
22 equipment is not in full working order it does not matter
23 that it remains that way for months at a time?
24 A. I think it depends on what part of it is not working.
25
26 Q. But if it turns out that it is an important part of the
27 machine; for example, if an insulated plastic handle that
28 had been deemed to be vital for employees' safety?
29 A. If I knew that a piece of equipment needed to be
30 insulated in a particular way to prevent an electric shock
31 and this was the situation, I would be concerned about it,
32 yes.
33
34 Q. Would it concern you if an electrical unit was plugged in
35 with a lead across, trailing across the floor, the kitchen
36 floor?
37 A. It would present a hazard if a lead was across a walk
38 way.
39
40 Q. I mean, these wires, leads, trailing across the floor, that
41 happens quite a lot, does it not, in McDonald's?
42 A. No. It very rarely happens in McDonald's.
43
44 Q. You have seen it happen?
45 A. I cannot recollect a time that I have seen a lead
46 trailing across a floor at all. The reason I say that is
47 that all the leads are, sort of, within the unit and
48 plugged into the wall or they go into the ceiling. So, to
49 have leads across the floor is unusual. In the dining
50 area, if you have an electric scrubber, then a lead may be
51 across the floor as you go around as you would if you were
52 hoovering the carpet at home, or sometimes outside if you
53 are steam cleaning with electrical equipment, you would
54 have a lead behind you. But, in the kitchen all the
55 equipment and the wires are really encased and away and are
56 not across walk ways.
57
58 With the fat filtering machine that you are referring to,
59 the plug is next to, is actually situated on the station
60 that you will be filtering, so the machine would be, the
