Day 128 - 24 May 95 - Page 11


     
     1        be practical of me to say we could keep all those areas
     2        clean, clean in terms of no debris at all.
     3
     4   MR. JUSTICE BELL:  What I was going to ask is, were the change
     5        in flooring and the non-slip soles seen as alternative
     6        solutions to a possible problem, or were they investigated
     7        also as two precautions which could be taken together?
     8        A.  They were not looked as an either/or.  We could have
     9        done both of them, there is no doubt.
    10
    11   MS. STEEL:   It would be fairly simple to provide a brush and a
    12        cloth, so that if crew members do tread in something they
    13        can clean it off immediately afterwards?
    14        A.  Yes, you could.  Whether they would do it is a
    15        different matter.  Again you are coming back to instead of
    16        eliminating the risk which, if we put the floors down and
    17        we maintain them, the risk is very much eliminated, versus
    18        bringing in shoes where you are then depending on a
    19        procedure, again, a procedure you do not necessarily have
    20        any control over.
    21
    22   Q.   The shoes is an additional measure though, you still get
    23        some slips and falls?
    24        A.  Yes, we do.
    25
    26   Q.   A fairly considerable number?
    27        A.  Well, they still make up, as we said, 40 per cent of
    28        our serious accidents, but remember as well one of the
    29        things we specify to our crew is that they wear shoes with
    30        slip resistant soles anyway.
    31
    32   Q.   But you are not prepared to provide them for them?
    33        A.  But we do not pay for them, no, but they are part of
    34        the uniform requirement.
    35
    36   Q.   Right, but they would be more likely to keep them clean if
    37        they were not wearing them outside to X, Y, Z, wherever it
    38        is they go when they were not working at McDonald's, if
    39        they were just provided for use in the store?
    40        A.  That I do not know.
    41
    42   Q.   That is realistic, is it not?
    43        A.  I do not know.  I would suspect -- I am just trying to
    44        put myself in this position -- if I had shoes just for
    45        work, they might be left at work and not taken away to be
    46        cleaned.
    47
    48   Q.   Would you could have cleaning facilities on site and the
    49        crew members could clean them during their working time, so
    50        they would be paid for it,  so they would not be thinking: 
    51         "I want to skimp on that because I am having to spend time 
    52        here cleaning my shoes when I am not getting paid for it"? 
    53        A.  It is an argument that could be put forward, I am sure.
    54
    55   Q.   But it would cost you money, of course?
    56        A.  It would cost some money.
    57
    58   Q.   What about providing shoes with rubber soles to lessen the
    59        effect of electric shock?
    60        A.  Well, that certainly is something we have not looked

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