Day 070 - 20 Dec 94 - Page 26


     
     1        industry and, obviously, by extension, McDonald's
     2        concerning workers' safety are not good, so it is entirely
     3        relevant.
     4
     5        I do not think this sheet that has been disclosed -- I do
     6        not want to go on at length -- I think I would describe it
     7        as laughable in terms of complying with what the intention
     8        is to get accurate information about accidents in the
     9        Plaintiffs's business.  In their own Operations Manual on
    10        page 156 -----
    11
    12   MR. JUSTICE BELL:  Give me the full reference.
    13
    14   MR. MORRIS:  Pink volume X, page 156.  I do not know if you want
    15        to have a look at it?
    16
    17   MR. JUSTICE BELL:  Yes.
    18
    19   MR. MORRIS:  The whole page is about safety.   "Safety losses"
    20        talks about: "By keeping accurate statistics, we have been
    21        able to measure the most frequent and costly ones" -- which
    22        I presume they mean accidents --  "which are shown in the
    23        accompanying chart" -- implying that they have accurate
    24        statistics which show what is shown in the chart, which is
    25        specific types of accidents, how frequent they are; and
    26        then of course they put them in a table of frequency and
    27        severity.
    28
    29   MR. JUSTICE BELL:  What date is this document?
    30
    31   MR. MORRIS:  1990/1991, it says at the beginning.  The first
    32        three in the chart are to do with employee accidents, and
    33        the last one is to do with customers, but, obviously, in
    34        this application we are concerned with the employees'
    35        accidents.
    36
    37   MR. JUSTICE BELL:  What about the United States then?
    38
    39   MR. MORRIS:  This is the UK and the United States Operations
    40        Manual, as far as I understand it.  It is identical.
    41
    42   MR. RAMPTON:  My Lord, it does not need, with respect, more than
    43        what one has got.  Once one sees what the numbers are for
    44        each year in this country and one sees what the frequency
    45        is -- and although this is an American document, from the
    46        nature of the business it is likely that frequencies are
    47        going to be similar over here -- once one is told, as you
    48        will be and the Defendants already have been, what a RIDDOR
    49        accident is, one does not really need any more information
    50        than that. 
    51 
    52   MR. JUSTICE BELL:  Where is the ranking?  Where do I find out 
    53        what the ranking numbers mean?
    54
    55   MR. RAMPTON:  Whether one is the least or the most serious?
    56
    57   MR. JUSTICE BELL:  Yes.
    58
    59   MR. RAMPTON:  I cannot tell your Lordship that.
    60

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