Day 207 - 23 Jan 96 - Page 55
1
2 Q. But you would have to take part in one if you were in the
3 store?
4 A. If I was in the store and one was performed, I would
5 take part in it.
6
7 Q. Then if you turn to page 205 -----
8
9 MR. JUSTICE BELL: Is Bath all on one floor, or does it have a
10 lower floor or an upper floor?
11 A. There is, basically, the restaurant ground level as you
12 walk in; there is the counter area; then there is a top
13 dining area; and, as you walk up the back stairs, there is
14 a landing that takes you into the top ---
15
16 Q. So there is an upstairs?
17 A. -- top lobby, and then you go up into the crew room
18 again, and there is a sort of mini-level where the trash
19 room and the back door entrance is, in between the lower
20 restaurant ground and the back door -- sort of split
21 levels.
22
23 MS. STEEL: If you look at page 205, under "Health and
24 Safety": "No knowledge of COSHH. Not enough plasters and
25 of the right shape. All of it is locked in the office.
26 Crew do not feel Managers take it seriously." Do you
27 remember that complaint?
28 A. No.
29
30 Q. Is that right that the Accident Book and First Aid kit are
31 locked in the office?
32 A. The First Aid equipment and the Accident Book are kept
33 downstairs in the office in the righthand cupboard, and the
34 additional First Aid plasters, et cetera, are kept upstairs
35 in the office.
36
37 Q. The office downstairs is, what, generally kept locked?
38 A. No, it is an open plan office; you can just walk -- any
39 member of staff can just walk straight in. It actually
40 connects to the kitchen area.
41
42 Q. So, is the upstairs office kept locked, where the plasters
43 are kept?
44 A. The plasters are kept downstairs and there is an
45 additional stock of plasters kept upstairs.
46
47 Q. But where it is referred to as "locked in the office", do
48 you remember a problem?
49 A. No.
50
51 Q. Any complaints of crew not being able to get plasters or
52 the Accident Book?
53 A. No.
54
55 MR. JUSTICE BELL: Well, in one of the audits, they are marked
56 down because they have run out of plasters.
57
58 MR. MORRIS: On page 178, it says "no plasters".
59
60 MR. JUSTICE BELL: But you do not remember any discussion about
