Day 209 - 25 Jan 96 - Page 36


     
     1   Q.   Did the four people scheduled, of whom one was already
     2        sick, include you?  Were you in that four?
     3        A.  No, no, I was not in that four.
     4
     5   Q.   What?
     6        A.  No, I was not in that four.
     7
     8   Q.   So it was plus you and another Floor Manager, was it?
     9        A.  Yes.  I just remember looking at the schedule, knowing
    10        that someone was going be ill, I looked down and I just saw
    11        three people for the close; and I do not mean that were
    12        there at the time; they have "CL" written beside their
    13        schedule.  It is "4" and then a little dash and a "CL"
    14        meaning "close", and they are the people you have after 11
    15        p.m. to close the store.
    16
    17        There were -- I think the Supervisor at the time had given
    18        us some -- was it that time?  There were a lot of cleaning
    19        tasks to be done on a night shift.  It was not just quickly
    20        clean everything, wash up and go home.  Everything in the
    21        kitchen had to be stripped and taken to the back room sinks
    22        and washed and sanitised and air dried; everything on the
    23        front had to be stripped and cleaned; and all the stainless
    24        steel had to be Ajaxed; the whole lobby area had to be
    25        redone, all the bins, et cetera; the trash room upstairs,
    26        the back-ups, where all the stocks are kept, that had to be
    27        organised.  You know, there were a great deal of things to
    28        do, and with few people to do it -- and I would not able to
    29        do those things; I would be doing the paperwork most of the
    30        time.  So it would just leave you with a lot of stress.
    31        People tended to be very tired with a great deal of work to
    32        do after 11.00.  It was just the final straw, that was
    33        all.
    34
    35   MR. MORRIS:  Shall I read on?
    36
    37   MR. JUSTICE BELL:  Yes.
    38
    39   MR. MORRIS:  Continuing to read: "Even when the store is at its
    40        quietest, it requires a bare minimum of four employees to
    41        operate:  one person to cover the kitchen, one to cover the
    42        till, one to cover the dining area, and one to control
    43        production and wrap the food.  Under-manning, especially at
    44        night, means only a few people are left to close the
    45        store.  This lack of staff is dangerous, as closing
    46        involves the use of machinery and hazardous cleaning
    47        chemicals by staff who are tired and rushing to finish, as
    48        they still have the same amount of work to complete but
    49        with less people to do it."
    50 
    51        Question 2 ----- 
    52        A.  I am saying that, because sickness was, on closes, 
    53        quite a problem.  People no showing for closes was more of
    54        a problem than no showing for a day shift, because closes
    55        were quite unpopular.
    56
    57   Q.   Question 2:  "On how many occasions did you find that
    58        out-of-date food had to be used?"  Answer: "It was common
    59        practice to try and sell salad from the day before if too
    60        many had been made.  On several occasions I informed the

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