Day 086 - 09 Feb 95 - Page 10


     
     1        was under-stocked -- not a grave concern but of concern.
     2
     3   Q.   Would it concern you if there is no salaried manager on
     4        duty in a store at a particular time?
     5        A.  No, that would not be a cause for concern.
     6
     7   Q.   There is no policy on that?
     8        A.  No, floor managers are trained to be able to manage
     9        shifts in restaurants.
    10
    11   Q.   Has that always been the case?
    12        A.  As far as I have known it, yes.
    13
    14   Q.   Would it concern you if a store was under-staffed?
    15        A.  Yes, it would be a source of concern.
    16
    17   Q.   Would it concern you if people had to rush to finish a
    18        close?
    19        A.  Sorry?
    20
    21   Q.   Would it concern you, we are talking about health and
    22        safety considerations, if staff had to rush to finish a
    23        closing time?
    24        A.  Well, it is a very general question but there would be
    25        a level of concern.
    26
    27   MR. JUSTICE BELL:  These are all concerns from the health and
    28        safety point of view, do you understand?
    29        A.  Yes.
    30
    31   Q.   When Mr. Morris says would it be a concern, he means from a
    32        health and safety point of view.
    33        A.  Well, he did not make that clear when he asked the
    34        question.  He just said in general was it a concern to me
    35        personally on this hypothetical situation.
    36
    37   MR. JUSTICE BELL:  Go back to the beginning then, Mr. Morris.
    38
    39   MR. MORRIS:  We talked about first aid.  That is to do with
    40        health and safety, is it not?
    41        A.  Right.
    42
    43   Q.   So that would concern you, under-staffing; would that
    44        concern you in terms of health and safety?
    45        A.  No, not really.
    46
    47   Q.   If under-staffing led to an increased work-load and
    48        pressure to cut corners on safety matters, would that
    49        concern you?
    50        A.  In my experience, it does not; it is a big assumption 
    51        to assume that that is the case. 
    52 
    53   Q.   So, if a store is under-staffed, presumably, that would
    54        mean that the current staff would not be able to do all the
    55        jobs, whether it is calibrations, safety matters, not run
    56        all the other things which you have mentioned, is not that
    57        correct?  That is the definition of under-staffing, not
    58        enough staff to do the work needed?
    59        A.  They may well just serve customers slower.  I mean,
    60        there are many things that would happen as a result of

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