Day 132 - 07 Jun 95 - Page 49


     
     1   Q.   Just glance at the first two paragraphs.
     2        A.  Yes.
     3
     4   Q.   Then the third para.:  "The financial standing of the
     5        situation will not be considered where electrical safety is
     6        concerned.  Your M & R account is no protection.
     7        Electricity kills and with 30,000 plus employees the odds
     8        of a fatal accident are high.  Please do not let one of
     9        your people be the first".  Do you see that?
    10        A.  Yes, I do.
    11
    12   Q.   From your experience of McDonald's and its attitude to
    13        employee safety, does that strike any discord in your mind?
    14        A.  None at all.  It reinforces the points that have been
    15        made.
    16
    17   Q.   Finally on this topic page 773 which is Frank Frost's memo
    18        which Mr. Morris did not show you but I will.  It is dated
    19        17th February 1992.  Do you see that?
    20        A.  Yes, I do.
    21
    22   Q.   Mr. Morris quoted imperfectly from the first part of it.
    23        He said Mr. Frost said that he is a northern region
    24        person.  He heads it, do you see, "important" with
    25        exclamation marks and asterisks?  "There have been several
    26        recent instances in our restaurants where members of staff
    27        have received severe shocks from faulty items of electrical
    28        equipment. Unfortunately, I have not been informed of these
    29        accidents at the time they occurred."
    30        A.  Yes.
    31
    32   Q.   Then do you see the words "AND" underlined?
    33        A.  Yes.
    34
    35   Q.   Could you read those carefully to yourself, please?
    36        A.  I do.
    37
    38   Q.   Then please read the last paragraph which is in ordinary
    39        lower case letters?
    40        A.  Yes.
    41
    42   Q.   My question is this.  From your point of view as an expert
    43        in health and safety, had you been in Mr. Frank Frost's
    44        position would you have worded that memorandum any
    45        differently?
    46        A.  No, I do not think I would.  I think that is a good
    47        memo in that particular instance.
    48
    49   MR. RAMPTON:  My Lord, those are all the questions I have.
    50 
    51   MR. JUSTICE BELL:  Thank you, Mr. Purslow. 
    52 
    53                            (The witness withdrew).
    54
    55   MR. MORRIS:  Just before we leave Mr. Purslow's evidence, the
    56        Health & Safety Commission report we have Mr. Rampton's
    57        copy.  Could we have a photocopy of it?
    58
    59   MR. RAMPTON:  I do not propose to photocopy the whole of it, my
    60        Lord.

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