Day 136 - 16 Jun 95 - Page 21


     
     1   Q.   Would you be called in if there was a particular problem in
     2        a particular store?
     3        A.  What would that particular problem be?
     4
     5   Q.   If there is a problem of people having accidents in a
     6        particular area?
     7        A.  What particular area are we talking about?
     8
     9   Q.   Any particular area; would you be called in?  Would someone
    10        call you and say -----
    11
    12   MR. JUSTICE BELL:  Why not ask him if he has ever been called
    13        in?
    14
    15   MR. MORRIS:  Have you ever been called in; "We have a problem;
    16        people keep slipping over in this area.  I think we ought
    17        did redesign the tiling for that purpose"?
    18        A.  No, I have never been called in in that specific
    19        situation.  I have been called in to identify tiles used in
    20        specific areas.
    21
    22   MR. JUSTICE BELL:  Yes, I understand that.  If there has been a
    23        fall, whoever is enquiring into it on behalf of the Company
    24        would want to know just what the tiling is, so you are
    25        asked to go along and identify it?
    26        A.  Yes, and sometimes it is not even necessary to go
    27        along.  You can always check back on the records.
    28
    29   Q.   No, you can look at the records.
    30        A.  Yes.
    31
    32   MR. MORRIS:  The specific circumstances of the Epsom accident
    33        you know nothing about?
    34        A.  No.
    35
    36   Q.   You did not visit the store around that time?
    37        A.  No.
    38
    39   Q.   Can we go to some documents that were disclosed in the last
    40        few days?  The Health and Safety Task Force Minutes.  I do
    41        not know where they have been put.  They have a "(d)" on
    42        them, I think.
    43
    44   MR. JUSTICE BELL:  Do we have a reference for where they are?
    45
    46   MR. RAMPTON:  My Lord, Mrs. Brinley-Codd gave Mr. Morris a list
    47        of references yesterday.  I do not know what he has done
    48        with them.  I am afraid I do not have it here.  Yes, my
    49        Lord, pink XIII, tab 57 V, that is the minutes.
    50 
    51   THE WITNESS:  What tap, did you say? 
    52 
    53   MR. JUSTICE BELL:  57 V.  Yes, Mr. Morris?  Do you have a page
    54        or a date?
    55
    56   MR. MORRIS:  I just want to ask a question first before we go to
    57        a page.  Do you know which members of staff have the
    58        highest incidence of slips and falls?
    59        A.  No, I am not aware, but I assume it is probably staff
    60        working in the kitchen.

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