Day 130 - 26 May 95 - Page 40
1 uncovered drain in the trash room". Is that something that
2 is quite normal, that there is an uncovered drain?
3 A. Normally they have a grid on the top of them.
4
5 Q. I think that is all I wanted to ask on that particular
6 except for -- I looked at Gloria Saul accidents?
7 A. Yes, she seemed to have recorded quite a few.
8
9 Q. Nineteen -- Mr. Rampton was absolutely right.
10
11 MR. JUSTICE BELL: It is strange, if you look through, she
12 appeared in two adjacent entries. On AAF Kevin Bellfall
13 appears twice in succession, and on an earlier occasion you
14 have the same person appearing twice in succession.
15 Whether they develop a taste for accidents or a taste for
16 the accident book I do not know, but it does happen with
17 different crew members.
18
19 MR. MORRIS: Maybe crew members, from time to time, remember to
20 report accidents and at other times they forget to report
21 accidents?
22 A. As I said before, I am sure that, looking at this
23 accident book there would have been other minor accidents
24 that have not been put in.
25
26 MR. JUSTICE BELL: There was always the person at school who
27 stepped off the wall bars, forgetting he was six feet off
28 the floor. You do get people like that. It could be for
29 any number of reasons.
30 A. It is really, the outcome of an accident is luck, you
31 know, whether it is just a small injury or something a
32 little more serious. It is really down to luck and ----
33
34 MR. MORRIS: When you looked through, did you notice the Gloria
35 Saul entries?
36 A. I did notice them.
37
38 Q. You noticed them. You said that she was fairly diligent,
39 she seemed to be diligent in reporting her accidents. Did
40 you notice her experience might be a fairly typical
41 worker's experience at McDonald's, with a truthful
42 reporting of it.
43 A. I think if you work out the numbers, if you are saying
44 the average is about 100 a year per store, and the average
45 number of employees is somewhere between 50 and 80, then
46 you would expect an employee to have a minor accident book
47 injury, something like a small cut or a small bruise, once
48 or twice a year. I think Gloria's, over the term of book,
49 probably works out about two per year, but there is no way
50 of telling whether she is a little more prone than most
51 people to have accidents.
52
53 MR. JUSTICE BELL: She had three in the first six months of
54 1992. None of this is any comment against her. It is bad
55 luck.
56 A. If you do have accidents -- we have talking averages
57 now -- I am sure the likelihood is you could have two
58 quite close together and then not have one for a very long
59 time.
60
