Day 128 - 24 May 95 - Page 04


     
     1   Q.   Why should you want to get the quarter pounder patty out of
     2        the grease trough?
     3        A.  It seemed silly leaving it there.  I was looking to put
     4        it in the red bin that we use for waste.
     5
     6   Q.   What about the other accidents?
     7        A.  I know I cut myself when I was cleaning the shake
     8        machine once.  Just on the inside door, I caught my finger,
     9        just a nick, on the sharp edge.
    10
    11   Q.   Then what about other burns and cuts?
    12        A.  I remember getting again a burn off a toaster, but
    13        again I put my finger on the top of the toaster.  I knew it
    14        was hot.  It was in my first few weeks there.  I knew it
    15        was hot but I put my finger on it anyway.
    16
    17   Q.   Because you were intent on doing your job?
    18        A.  I probably just was not thinking what I was doing, and
    19        I just got a small burn on my fingers.
    20
    21   Q.   What about any other burns and cuts?
    22        A.  I cannot remember any others specifically.
    23
    24   Q.   No other cuts?
    25        A.  No.
    26
    27   Q.   Would you say you are pretty average or accident-prone, or
    28        particularly careful?
    29        A.  I have accidents just like anybody else.  Most of them,
    30        I have to say, are at home.  In fact, the worst burn I ever
    31        had, which I still have a scar on my arm from, was at
    32        home.  I certainly have more accidents at home then
    33        anywhere else.  I would not say I was particularly
    34        accident-prone or not accident-prone.
    35
    36   Q.   Did you enter all those accidents in the accident book?
    37        A.  I really -- I cannot remember.
    38
    39   Q.   Yesterday -- I do not know -- I got the impression that you
    40        did not seem to think they really counted as accidents
    41        because they were not very severe?
    42        A.  Well, it depends what your definition of "accident" is
    43        and, certainly, we would look on accidents as being an
    44        unplanned event which could lead to an injury, it could
    45        lead to something else, it could lead to damage.  If
    46        somebody dropped a toaster on the floor, you could still
    47        call it an accident, but it would not necessarily result in
    48        injury.
    49
    50        The accident book is such, as my understanding of it, from 
    51        a legal requirement, is for injuries to be put in there 
    52        and, yes, you could argue that those injuries result from 
    53        accidents; it is just one particular sort of accident
    54        though.
    55
    56   Q.   Right, but in terms of that type of injury, would you call
    57        that an accident, or would you just think it was not severe
    58        enough to be particularly worried about in terms of making
    59        a note of it or reporting it?
    60        A.  The sort of accidents I just described to you, although

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