Day 006 - 05 Jul 94 - Page 06
1 kitchen or fallen over and injured themselves, do you see,
then very different considerations might be applied, might
2 be readily available. One might see it and then decide
whether it has been useful. In fact, now is there any
3 kind of documentation like that?
A. There may be; I have not seen one. I do not imagine
4 there is one. It may very well be that something has
existed. I do not recall ever seeing one, sir.
5
MR. MORRIS: I just bring up a document that was referred to
6 when Mr. Beavers was in the witness box. Just to save
time, I do not think we have to find the document. It was
7 read out at the time, you may remember. I think you were
in the court at the time?
8 A. I do not know what you are referring to.
9 Q. Document operations manual from the States. I read out a
page about safety charts, employees burned by heat
10 equipment, employees injured by contact with equipment. I
quoted a line which said: "By keeping accurate statistics
11 we have been able to measure the most frequent and costly
accidents which are shown in the accompanying chart".
12 This operations manual is the operations manual not only
for the US, is it also for this country?
13 A. It is, in so far as it is practical to apply it, yes.
Some bits of it do not apply here.
14
Q. Have you asked Andrew Taylor if he has national statistics
15 compilations?
A. No.
16
Q. As suggested in the operations manual?
17 A. No, I have not asked him that. I would guess the one
place there might be some statistics are with our
18 insurers; that is a possibility. But I am not even
hundred per cent sure of that. They must have something
19 but I do not know exactly what it would be.
20 Q. It might be useful to get file XIII, that is 13, I do not
know the colour -- it is pink 13, tab 55?
21 A. OK, 55.
22 Q. Have you got tab 55?
A. I do, yes.
23
Q. I am not sure I need refer to it in detail at this moment
24 but -----
25 MR. JUSTICE BELL: What I suggest you do is concentrate on
anything upon which you think Mr. Preston specifically may
26 help you in relation to it.
27 MR. MORRIS: Yes. This is a document, is it not, called
document Management of Occupational Health & Safety,
28 McDonalds' Restaurants, compiled by the Health & Safety
Executive, August 1992, accident prevention advisory unit?
29 A. Yes, August 1992.
30 Q. If you turn over the page in its conclusions and
recommendations under 5.3 the last sentence says: "There
