Day 086 - 09 Feb 95 - Page 14


     
     1        health and safety expert a handle such as that could have
     2        prevented someone's death if it had been there, would that
     3        concern you?
     4        A.  If a health and safety professional said that, it would
     5        obviously concern me, if that was his opinion.
     6
     7   Q.   If it had been missing for months, would that have
     8        concerned you even more?
     9        A.  No, I do not think so.
    10
    11   Q.   But would it concern you that if a piece of important
    12        equipment, whether a handle or whatever, which is needed
    13        has not been fixed for months, would that indicate to you a
    14        breakdown of some kind of management responsibility in
    15        the -----
    16
    17   MR. JUSTICE BELL:  Just sloppiness -- would it indicate
    18        sloppiness to you?
    19        A.  On its own, no.
    20
    21   MR. MORRIS:  Are you saying that if a piece of electrical
    22        equipment is not in full working order it does not matter
    23        that it remains that way for months at a time?
    24        A.  I think it depends on what part of it is not working.
    25
    26   Q.   But if it turns out that it is an important part of the
    27        machine; for example, if an insulated plastic handle that
    28        had been deemed to be vital for employees' safety?
    29        A.  If I knew that a piece of equipment needed to be
    30        insulated in a particular way to prevent an electric shock
    31        and this was the situation, I would be concerned about it,
    32        yes.
    33
    34   Q.   Would it concern you if an electrical unit was plugged in
    35        with a lead across, trailing across the floor, the kitchen
    36        floor?
    37        A.  It would present a hazard if a lead was across a walk
    38        way.
    39
    40   Q.   I mean, these wires, leads, trailing across the floor, that
    41        happens quite a lot, does it not, in McDonald's?
    42        A.  No.  It very rarely happens in McDonald's.
    43
    44   Q.   You have seen it happen?
    45        A.  I cannot recollect a time that I have seen a lead
    46        trailing across a floor at all.  The reason I say that is
    47        that all the leads are, sort of, within the unit and
    48        plugged into the wall or they go into the ceiling.  So, to
    49        have leads across the floor is unusual.  In the dining
    50        area, if you have an electric scrubber, then a lead may be 
    51        across the floor as you go around as you would if you were 
    52        hoovering the carpet at home, or sometimes outside if you 
    53        are steam cleaning with electrical equipment, you would
    54        have a lead behind you.  But, in the kitchen all the
    55        equipment and the wires are really encased and away and are
    56        not across walk ways.
    57
    58        With the fat filtering machine that you are referring to,
    59        the plug is next to, is actually situated on the station
    60        that you will be filtering, so the machine would be, the

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