Day 128 - 24 May 95 - Page 63


     
     1
     2   MS. STEEL:  The other thing is a copy of the health and safety
     3        audit form and the personnel audit which had health and
     4        safety matters on it, according to Mrs. Barnes.  I have a
     5        feeling though there are some others.
     6
     7   MR. JUSTICE BELL:  Pick those up in the morning, if you want.
     8
     9   MS. STEEL:  The High Levels magazine and the Crew magazine, that
    10        is something that has been specifically referred to by
    11        Mrs. Barnes as somewhere where they were getting their
    12        health concerns about health and safety across to crew
    13        members and management, in order for them to take action.
    14        On those grounds I feel that they ought to be disclosed.
    15        They are being relied on by the Plaintiffs.
    16
    17   MR. JUSTICE BELL:  You do not want the lot.  What you are
    18        enquiring about is, you say Mrs. Barnes has said that,
    19        surely what you are enquiring about is whether there is any
    20        particular copy which she has in mind.  At the moment I am
    21        not too much in favour of that; the reason being that we
    22        have quite a lot of documentation which might help me, one
    23        way or the other, as to whether McDonald's was getting the
    24        question of health and safety across.
    25
    26        Although Mr. Rampton has an argument, which may well have
    27        merit, about the relevance of matters which have happened
    28        since 1990, I have to keep reminding myself that the
    29        leaflet was published in 1989/90, according to the
    30        allegation made against you and Mr. Morris.  At the moment
    31        what I am minded to say is I think that someone should look
    32        at a copy of the health and safety audit form and the
    33        personnel audit forms as well.
    34
    35        In fact, I really do not see why copies of those should not
    36        be shown to Ms. Steel and Mr. Morris.  I do not know how
    37        long they are.
    38
    39   MR. RAMPTON:  My Lord, we will look at all these documents.  We
    40        will look at the full report of which these three sheets
    41        and 57M -----
    42
    43   MR. JUSTICE BELL:  I am not terribly interested in the magazines
    44        at the moment because I have no way of knowing, even if
    45        they do appear in the magazines, how many crew members
    46        bother to read them.
    47
    48   MR. RAMPTON:  My Lord, I hope I have understood your Lordship's
    49        thinking.  If there is any relevance in it (and I have to
    50        say that I have to reserve my position about that), what 
    51        your Lordship would be interested in would be what I might 
    52        call "hard data" about the safety of the operation for the 
    53        people who run it, and about, as it were, the Company's
    54        internal concerns, to use it in its modern sense, and
    55        careful interests of their own employees, which your
    56        Lordship is not going to find except in the form of, sort
    57        of, public statement in the Company magazines.
    58
    59   MS. STEEL:  If I could make a suggestion which is that,
    60        obviously, it might take some time for those to be

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