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,

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