Day 130 - 26 May 95 - Page 30


     
     1        formally in writing, but certainly to look into the
     2        circumstances of each one of them.
     3
     4   Q.   Did you actually, as you were going through it, notice that
     5        there is a very substantial percentage, the vast majority
     6        seem to be burns, slips and falls?
     7        A.  Burns is an outsome, so you could have a slip accident
     8        where you got a burn, but if you think of the hazards that
     9        are in our kitchens, it is not surprising that those are
    10        the most frequent types of accidents because there is not
    11        very much else to injure.
    12
    13   MR. RAMPTON:  If it would be of any help, I have counted them
    14        up.  I am not saying my figures are necessarily 100 per
    15        cent.
    16
    17   MR. JUSTICE BELL:  Give them to me, and if it is challenged in
    18        due course, at least there is something to work on.
    19
    20   MR. RAMPTON:  I counted 64 burns, 57 cuts, 34 bruises, 19
    21        sprains, in which I included things like hurt back and that
    22        kind of thing, and two electric shocks.  I excluded unusual
    23        sorts of things which occur only once.  I gave those
    24        general categories as perhaps, I know not, being the more
    25        typical kinds of injuries.  I also excluded any customer
    26        accidents.
    27
    28        My Lord, the percentages are burns 36, cuts 32, bruises 19,
    29        sprains 11 and shocks 1, making 99 per cent, because I have
    30        rounded up or down as I went along.
    31
    32   MR. JUSTICE BELL:  What was it after bruises?
    33
    34   MR. RAMPTON:  I called them sprains, which is a generic term for
    35        sort of twisted wrist and hurt backs, and that sort of
    36        thing.
    37
    38   MR. JUSTICE BELL:  If you ask me what the most likely accidents
    39        were in a kitchen or eating area, I would have said burns
    40        because there is hot equipment and fat there, cuts because
    41        you use sharp implements, and slips because, in any place
    42        where you are cooking or eating, wet or eating matter can
    43        end up on the floor and someone can slip or fall as a
    44        result of it.
    45        A.  Yes.
    46
    47   Q.   I do not suppose McDonald's is any different to anywhere
    48        else; you have got the possibility of electric shocks,
    49        which has now been very extensively canvassed as an area of
    50        its own. 
    51        A.  I would say that is a pretty accurate summing up, sir. 
    52 
    53   Q.   All the slipping accidents I have ever had as a barrister
    54        were in restaurants, in shops, particularly green grocery
    55        shops, or hospitals, wet or shiny floors, that sort of
    56        thing.
    57        A.  Yes.
    58
    59   MR. MORRIS:  If we just turn through the pages of this, we can
    60        note that in the early few pages there is a lot of people

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