Day 070 - 20 Dec 94 - Page 26
1 industry and, obviously, by extension, McDonald's
2 concerning workers' safety are not good, so it is entirely
3 relevant.
4
5 I do not think this sheet that has been disclosed -- I do
6 not want to go on at length -- I think I would describe it
7 as laughable in terms of complying with what the intention
8 is to get accurate information about accidents in the
9 Plaintiffs's business. In their own Operations Manual on
10 page 156 -----
11
12 MR. JUSTICE BELL: Give me the full reference.
13
14 MR. MORRIS: Pink volume X, page 156. I do not know if you want
15 to have a look at it?
16
17 MR. JUSTICE BELL: Yes.
18
19 MR. MORRIS: The whole page is about safety. "Safety losses"
20 talks about: "By keeping accurate statistics, we have been
21 able to measure the most frequent and costly ones" -- which
22 I presume they mean accidents -- "which are shown in the
23 accompanying chart" -- implying that they have accurate
24 statistics which show what is shown in the chart, which is
25 specific types of accidents, how frequent they are; and
26 then of course they put them in a table of frequency and
27 severity.
28
29 MR. JUSTICE BELL: What date is this document?
30
31 MR. MORRIS: 1990/1991, it says at the beginning. The first
32 three in the chart are to do with employee accidents, and
33 the last one is to do with customers, but, obviously, in
34 this application we are concerned with the employees'
35 accidents.
36
37 MR. JUSTICE BELL: What about the United States then?
38
39 MR. MORRIS: This is the UK and the United States Operations
40 Manual, as far as I understand it. It is identical.
41
42 MR. RAMPTON: My Lord, it does not need, with respect, more than
43 what one has got. Once one sees what the numbers are for
44 each year in this country and one sees what the frequency
45 is -- and although this is an American document, from the
46 nature of the business it is likely that frequencies are
47 going to be similar over here -- once one is told, as you
48 will be and the Defendants already have been, what a RIDDOR
49 accident is, one does not really need any more information
50 than that.
51
52 MR. JUSTICE BELL: Where is the ranking? Where do I find out
53 what the ranking numbers mean?
54
55 MR. RAMPTON: Whether one is the least or the most serious?
56
57 MR. JUSTICE BELL: Yes.
58
59 MR. RAMPTON: I cannot tell your Lordship that.
60
