Day 130 - 26 May 95 - Page 52


     
     1        electricity; they are things like working at heights; they
     2        are things like deliveries; they are things ------
     3
     4   Q.   You mean lifting heavy -----
     5        A.  Pushing roll cages.  Depending again, that very good
     6        example, it depends on the local set up in the restaurant.
     7        Deliveries can be very easy to do or, if it is an older
     8        store, have more difficulty, and need a bit more time from
     9        managers to control the rig.
    10
    11   Q.   These 15 -----
    12        A.  They are in ------
    13
    14   Q.   Sorry, is this in the safety audit?
    15        A.  Yes, they start on page 3.  You see, fire, safety,
    16        First Aid, floor maintenance, prevention of
    17        slips, general  -----
    18
    19   Q.   Hang on a second -- this is October 1994?
    20        A.  Yes, it is only changed very slightly from the original
    21        one in August 1993, which is the layout change.
    22
    23   Q.   Which are the ones you have identified as potentially
    24        hazardous?
    25        A.  Section B.
    26
    27   Q.   High risk activity, sorry?
    28        A.  Yes.
    29
    30   Q.   It is called high risk activities?
    31        A.  All of these are the areas we would expect, both
    32        managers and my people, when they are doing unannounced
    33        visits, to check up on.  They are not necessarily high
    34        risk, but they are areas that do have a high hazard, a high
    35        potential for causing injury.  They are areas we need to
    36        check on that are being controlled properly.
    37
    38   Q.   They are defined there as high risk activities?
    39        A.  Exactly.  They are the ones that could be high risk, so
    40        they need to be controlled.
    41
    42   Q.   The point is they are high risk, are they not?  The
    43        question is whether the risk becomes a reality.  That is
    44        where the potential comes in.  They are high risk
    45        activities.  That is what it says on your form?
    46        A.  I suppose you have turned it around against me there in
    47        terms of -----
    48
    49   MR. JUSTICE BELL:  It has to be comparable, has it not?
    50        A.  It has, yes. 
    51 
    52   Q.   Because, for instance, handling is 5, it falls within the 
    53        box brackets of Nos. 3 to 6, which at the top of the page
    54        we can see are causes of over 80 per cent of serious
    55        accidents.
    56
    57   MR. MORRIS:  Yes.
    58
    59   MR. JUSTICE BELL:  Obviously, one can see that there are a lot
    60        of accidents, particularly, I suppose, back injuries and

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