Day 136 - 16 Jun 95 - Page 22


     
     1
     2   Q.   If we look in the minutes for 7th December 1992 -- these
     3        are not numbered by page -- it is about a third of the way
     4        through that bunch of documents, it has a page 1 on it, and
     5        it is the first of five pages for that particular date.
     6        A.  First of what?
     7
     8   Q.   It is 7th December 1992 at the top right-hand corner.
     9
    10   MR. JUSTICE BELL:  It is about halfway through in fact, maybe a
    11        third.  They are in chronological order, Mr. Brown,
    12        I think.  Keep going until you come to 7th December 1992.
    13        A.  Yes.
    14
    15   MR. MORRIS:  You have that?
    16        A.  Yes.
    17
    18   Q.   If you look on page 1 it has two-thirds of the way down:
    19        "Unless health and safety is talked about in cost terms
    20        with hard figures, top management will not be
    21        interested."   Why, in your experience, would top
    22        management not be interested unless health and safety is
    23        talked about in cost terms with hard figures?
    24        A.  I have no idea.
    25
    26   Q.   If you turn over the page, under 4.2 "Accident Statistics",
    27        below the bit that has been blanked out above it, the first
    28        point:  "The Total has gone up by 20 per cent.  Floor
    29        managers and dining area hosts still have the highest
    30        incidence of slips and falls."   Do you not think, bearing
    31        in mind that McDonald's position at that time in 1982 was
    32        that dining area hosts as well as floor managers still have
    33        the highest incidence of slips and falls, that as they are
    34        working in the dining area most of the time that the dining
    35        area should also be fitted with slip resistant tiles as
    36        well as the other areas?
    37        A.  It says here:  "Floor managers and dining area hosts
    38        still have the highest incidence of slips and falls".  It
    39        does not say where they are having the slips and falls.
    40
    41   Q.   If it is a dining area host?
    42        A.  Well, it could be in the kitchen while the person is in
    43        the kitchen area, or it could be while they are having
    44        their meals in the crew room.
    45
    46   Q.   If a conclusion could be drawn -----
    47
    48   MR. RAMPTON:  My Lord, I have some doubt as to whether this is
    49        the right witness to cross-examine about this topic.
    50 
    51   MR. JUSTICE BELL:  Yes. 
    52 
    53   MR. MORRIS:  Unfortunately -----
    54
    55   MR. RAMPTON:  It is pure speculation.  It is not speculation; it
    56        is comment, in effect.  Your Lordship may well conclude
    57        that the likeliest place for the dining area person to
    58        spend most of their working day is in the dining area, I do
    59        not know.
    60

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