Day 001 - 28 Jun 94 - Page 46


     
     1        is no, the plaintiffs' rates of pay, wherever in the
              world, are and always have been above minimum and
     2        represent a fair award for a fair day's work.
 
     3        What is perhaps just as important is the plaintiffs'
              provide welcome job opportunities for many thousands of
     4        people throughout the world.  For many young people,
              particularly students, a job at McDonald's is ideal
     5        employment because they can work in hours of the day and
              times of the year which suit them.  The same, of course,
     6        is true of mothers with school age children.
 
     7        The second question:  Are the plaintiffs' policies and
              practices in relation to the health and safety of their
     8        employees open to serious criticism?  What one might call
              health and safety at work.  Again, my Lord, the answer is,
     9        no.  Any restaurant which serves food, particularly if it
              serves it quickly, presents some potential hazard and
    10        injury, that is obvious.  There are, after all, hot
              grills, hot fat, sharp instruments, floors which are
    11        sometimes slippery and often many people to be served in a
              great hurry.
    12
              However, the plaintiffs' thorough training programme on
    13        employees' safety, which are uniformed throughout the
              world, and the disciplined application of those programmes
    14        in the restaurant mean that these inherent hazards are
              kept to a bare minimum.
    15
              Witnesses of the plaintiffs will describe the programmes.
    16        Mr. Chris Purslow (whose reference is yellow bundle X/40
              and 41) is an independent environmental health consultant
    17        who has examined the plaintiffs' procedures and inspected
              a selection of their restaurants in action.  He will
    18        confirm that the plaintiffs' policies and practices in
              relation to the safety of their employees are extremely
    19        good.
 
    20        My Lord, of course, this does not mean that accidents
              never happen.  It is perfectly natural that they should
    21        and they do.  My Lord, once again, however, one has to
              look at this as a question of proportion.  One has to look
    22        at it in the context of the size of the plaintiffs'
              operation worldwide.  I remind your Lordship that the
    23        plaintiffs have about 14,000 restaurants in 70 countries
              around the world.
    24
              It is estimated that the average number of employees per
    25        restaurant is about 60 people.  This means that the total
              number of employees in the restaurant in the world at any 
    26        one time is about 840,000. 
  
    27        My Lord that is a huge potential base for accidents at
              work.  My Lord, yet what are the defendants able to
    28        allege?  Your Lordship will notice that I ignore the
              question at this stage:  What are they actually able to
    29        prove?
 
    30        What they are able to allege is something like a dozen
              accidents and injuries, some serious certainly, but most

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