Day 085 - 08 Feb 95 - Page 26


     
     1        and everyone else investigate or talk about the accidents
     2        and how to make the place more safe.  It may have been in
     3        some stores that they identified that the lunch-time period
     4        is a particular time and that is something that should be
     5        prioritised.  Maybe another restaurant identifies that on
     6        the close there is a problem.
     7
     8   Q.   But, in terms of nationally, in terms of your position,
     9        with an overview of wanting to improve health and safety,
    10        you have not seen any reports on:  "When do accidents
    11        occur?"  or "When do the most serious accidents occur?" or
    12         "Do we need to look at this?"  Have you seen anything like
    13        that?
    14        A.  I do not have a graph that shows the time of day and
    15        the number of accidents.
    16
    17   Q.   So, all I am saying is that you have not seen any analysis
    18        of accident problems or potential accident problems with
    19        regard to timings?
    20        A.  In my six months in the position, no.
    21
    22   MR. JUSTICE BELL:  Just pause there because the reference to the
    23        example of how "hustle" was interpreted has caused me to
    24        look through the report and I may well have missed parts of
    25        it.  There is a section dealing specifically with "hustle"
    26        on page 828 starting at 2.39 and going on to page 830 on
    27        2.43.  I think you should just read that through.
    28        A.  From 828, 2.39?
    29
    30   Q.   2.39 to 2.43.  If you then in the light of it want to add
    31        to or modify any previous answers that you can remember,
    32        please do so.  Mr. Morris may or may not be going to ask
    33        you questions about that, but since you have not read the
    34        document, have a look at it now.
    35        A.  OK.  I have read that through.
    36
    37   Q.   It mentions, for instance, definitions given and
    38        redefinition.  Just pause a moment.  Before Mr. Morris
    39        continues, is there anything in the light of reading that
    40        that you want to add to anything you have said so far?
    41        I am not suggesting there should be; you are just being
    42        given the opportunity.
    43        A.  No, I do not think there is anything to add to that.
    44        It seems to be in my interpretation of "hustle" similar to
    45        what is here.  I have nothing to add to that.
    46
    47   MR. JUSTICE BELL:  Very well.
    48
    49   MR. MORRIS:  Just a final question on this document:  Does it
    50        concern you that you did not know of the existence of this 
    51        document? 
    52        A.  No, not at all. 
    53
    54   Q.   I did ask you before but I did not follow it through, have
    55        you made any criticisms of the McDonald's setup with regard
    56        to health and safety when you talk to other people higher
    57        than you or other departments, saying that you demand some
    58        changes to be made?
    59        A.  I think we looked at recommendations for improvement
    60        and specifically in the area of delivering safe products to

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