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
