Day 072 - 12 Jan 95 - Page 42


     
     1        term of art to McDonald's?
     2        A.  Yes.
     3
     4   MR. MORRIS:  I beg to differ.  It is relevant in this case.
     5
     6   MR. JUSTICE BELL:  It may be when you come to timing, yes.
     7
     8   MS. STEEL:  You are responsible for training at your store, are
     9        you not, of some sorts?
    10        A.  Well, I am in overall responsibility for all areas in
    11        the restaurant.
    12
    13   Q.   If you could get down the operations and training manual?
    14
    15   MR. JUSTICE BELL:  Can you give us a bundle, the reference?
    16
    17   MS. STEEL:  It is pink X.  The section on crew cleaning tasks
    18        outside the building begins on page 45.  Here it says:
    19         "The shift manager is responsible for assigning a crew
    20        person to perform the outside duties.  During high volume
    21        periods a full-time outside crew person is necessary."
    22        There was a mention in one of the letters referred to
    23        yesterday about somebody, a store in Norwich, employing
    24        someone on a full-time basis.  You said you had never heard
    25        of that before.  Do you recognise that this indicates that
    26        the Corporation -- I think this is an American document
    27        which applies to this country as well -- seems to think
    28        that a full-time outside crew person is a good idea if it
    29        is, you know, during high volume periods?
    30        A.  It does not define what the high volume would be, how
    31        high the volume would be.  I mean, I manage my restaurant
    32        on an individual basis.  You know, I follow the McDonald's
    33        guidelines but I do not -- it does not say that it is a
    34        requirement.
    35
    36   Q.   No, but it does not say it is not permitted either.  So, if
    37        the environment/index.html">litter is a particular problem in the Kings Road area,
    38        you could, in fact, employ someone on a full-time basis to
    39        ensure that the environment/index.html">litter is picked up?
    40        A.  There is nothing to stop me now if I wanted to employ a
    41        full-time person.
    42
    43   Q.   On page 47 under "boundaries of the restaurant" it says:
    44         "The outside person is to pick up all trash, not just
    45        McDonald's papers, from the side walks, landscaping, and
    46        street gutters for a distance of at least one block in
    47        every direction of the store".  This morning when I was
    48        asking you about where the environment/index.html">litter patrol extended to, you
    49        said that it did not go into the roads that were the other
    50        side of the Kings Road? 
    51        A.  That is correct, yes. 
    52 
    53   Q.   So that would appear to be in contravention of the
    54        operations and trainings manual?
    55        A.  I would have to know what one block was.
    56
    57   Q.   Is it not self-explanatory?
    58
    59   MR. RAMPTON:  No, my Lord, it is not self-explanatory.  It is a
    60        piece of American.  It is not English.  It is American.

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