Day 071 - 11 Jan 95 - Page 31


     
     1        hourly, minimum half hourly, following the store's trash
     2        walk map.
     3
     4   Q.   Where is that policy in writing?
     5        A.  When a crew member starts in a restaurant before he
     6        works in the dining area.  They have to complete what is
     7        called an observation check list which trains that crew
     8        member on the responsibilities of that job.  On that it is
     9        stated that it is their responsibility to ensure the trash
    10        walks are completed a minimum of half hourly following the
    11        trash walk map.  When a manager is trained from a trainee
    12        manager they have to go through this basic training
    13        themselves, so they are aware of the policy as well.  I am
    14        not 100 per cent sure on the company's literature where
    15        this is stated.
    16
    17   Q.   Where have you read it?
    18        A.  Well, I was trained, when I was a trainee using the
    19        OCLs, and also I went through a basic operations course
    20        which -- a trainee manager, to become an assistant manager
    21        you have to go through the basic operations course.  It is
    22        also stated on that course that that it is part of the
    23        manager's responsibilities and anyone working in the dining
    24        area to complete these trash walks.
    25
    26   Q.   Is there a set minimum distance that these trash walks have
    27        to cover?
    28        A.  There is not set -- to my knowledge, there is not a set
    29        minimum distance.  The store has to decide on average how
    30        far a customer would walk it would take to eat the meal
    31        walking from the restaurant.  That is how I believe it to
    32        be.
    33
    34   Q.   How do they work that out then?
    35        A.  Well, personally, in my restaurant, I tried it out.
    36        I took a meal and I walked and I could see how far I went.
    37        Also you can tell visibly how far the rubbish will go.
    38        Obviously, someone may go further than that with their
    39        meal, but you cannot measure exactly because people are
    40        different.
    41
    42   Q.   So far as you are aware, do most people start eating the
    43        meal immediately they leave the store?
    44        A.  Well, I cannot really comment on an average customer
    45        would eat their meal; some go by car, some go by foot, some
    46        eat their food right outside the restaurant in the summer.
    47
    48   Q.   So the 400 yards figure that you gave before, that was
    49        based solely on you starting to eat a meal outside the
    50        store and walking that distance? 
    51        A.  Not only that, no, also through my observations in the 
    52        area, how far the rubbish was carried and with the problems 
    53        of that area as well.
    54
    55   MR. JUSTICE BELL:  I was going to say, presumably, you can walk
    56        around the streets and see how far away any McDonald's
    57        environment/index.html">litter tends to be?
    58        A.  Yes.  I can also by speaking to local residents I can
    59        find out, you know, what their views are, how far they have
    60        seen rubbish away from the store, but it also depends on

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