Day 130 - 26 May 95 - Page 62
1
2 MR. MORRIS: I was using language the McDonald's use,
3 "targeted".
4
5 MR. JUSTICE BELL: A more significant answer -- you can
6 challenge it with evidence or comment in due course -- so
7 far as the productivity of asking Mrs. Barnes more about
8 this is concerned, she said a few moments ago: "I cannot
9 think of any examples of accidents from under-staffing".
10 So, as far as she is concerned, there is no safety problem
11 arising from under-staffing. At the end of the day, you
12 may point to some other evidence which persuades me that
13 I should not attach weight to that answer, but that is Mrs.
14 Barnes' point of view.
15
16 MR. MORRIS: All slips and falls could potentially be caused by
17 people having to run, for example?
18 A. The potentially could by all sorts of things. That is
19 why I depend on my regional people to monitor the accident
20 investigation reports, bring to our meetings any concerns
21 they have about national implications from those causes. I
22 have no evidence to show that rushing and running are
23 causes slips and falls.
24
25 As I said yesterday, going through our database, I can find
26 very few examples when anybody was doing anything but
27 walking. Secondly, I have no reason from what they have
28 told me to think under-staff is an issue either with regard
29 to safety.
30
31 Q. So in terms of your developing your risk management
32 programme, you have not even looked into -- never mind
33 under-staffing, we have dealt with that -- the functioning
34 of the targeted labour cost guidelines?
35 A. I do not know of any targeted cost labour guidelines.
36
37 Q. Yes. Well, Mr. Rampton just invented that. I am using the
38 words McDonald's used. I would call them "labour cost
39 ceilings". I would call them "targeted guidelines".
40
41 MR. JUSTICE BELL: Pause.
42
43 MR. MORRIS: Because this McDonald's position.
44
45 MR. JUSTICE BELL: Just take it easy for the moment, because
46 whether you are right or wrong about that, this witness is
47 saying she does not know about it.
48
49 MR. MORRIS: She does not know.
50
51 MR. JUSTICE BELL: So it is unproductive to ask her anything on
52 the basis of their existence.
53
54 MR. MORRIS: (To the witness): Going back to the
55 under-staffing -- it is related anyway -- have you
56 looked into specifically whether the level of staffing in
57 your statistics that you have looked at, or your enquiries,
58 is related to the accidents that happen, whether accidents
59 occurred at a time when there may have been two or three
60 people did not turn up and were not replaced or whatever,
