Day 084 - 07 Feb 95 - Page 38


     
     1
     2   MR. RAMPTON:  Yes.
     3
     4   MR. JUSTICE BELL:  I will move that across when we come to it.
     5        Thank you.
     6
     7   MS. STEEL:  The older observation check lists are in document
     8        117 of the Defendants' first list of documents.
     9
    10   MR. MORRIS:  Where we are putting this?  Is it 57-O?
    11
    12   MR. JUSTICE BELL:  I am going to put them at the back of this
    13        bundle with the ones which Mrs. Brinley-Codd has just
    14        handed up.  When you come to observation chick list
    15        I suggest we pause for a couple of minutes and get them all
    16        together in one place from the various bundles.  Are you
    17        going straight to that now.
    18
    19   MS. STEEL:  No, I am not.
    20
    21   MR. JUSTICE BELL:  Perhaps we could bear that in mind. If you
    22        are anxious to make it clear that it was one of your
    23        documents, the old one, when we do that remind me to write
    24        on top of it "Defendants' document".
    25
    26                       Cross-Examined by the Defendants.
    27
    28   MS. STEEL:  When you were giving evidence about the number of
    29        accidents in relation to the number of employees, you said
    30        that you have 32,000 employees working for us 364 days of
    31        the year and 16 hours per day.  You were not trying to
    32        suggest that all 32,000 employees were working those hours,
    33        were you?
    34        A.  Indeed I was not, no.
    35
    36   Q.   Most of your employees are part-time?
    37        A.  The majority are, yes.  The point was that the
    38        statistics, you had to consider the amount of time people
    39        working in the restaurants to put them into some sort of
    40        perspective.
    41
    42   MR. JUSTICE BELL:  Is the day missing Christmas Day or some
    43        other day?
    44        A.  Christmas Day.
    45
    46   MS. STEEL:  I think we may have had this before, but I am not
    47        sure.  Could you say how many hours the average employee
    48        works per week?
    49        A.  I am afraid I would not know that.
    50 
    51   Q.   You do not know? 
    52        A.  No. 
    53
    54   Q.   What are the most frequent accidents that occur in stores?
    55        A.  Slips, trips and falls.
    56
    57   Q.   What about burns?
    58        A.  I do not think they occur as frequently -- as regards
    59        reportable accidents it is slips, trips and falls.
    60

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