Day 132 - 07 Jun 95 - Page 12


     
     1   THE WITNESS:  My Lord, if I may make a comment?
     2
     3   MR. JUSTICE BELL:  No, do not at the moment.  They must have
     4        interviewed crew members.  They say on the top of page
     5        100:  "Interviews with managers and other employees", and
     6        some of the answers could only have come from crew members?
     7        A.  Page 808 elucidates it, my Lord, in the second
     8        paragraph, where they say:  "During the site visits to
     9        restaurants a sample of crew and managers were interviewed
    10        to establish what actually happened in practice".
    11
    12   MR. MORRIS:  What page is that?
    13        A.  Page 808, in the second paragraph.
    14
    15   MR. JUSTICE BELL:  They obviously have not listed the crew
    16        members on their list of people interviewed; they have
    17        listed the executives.
    18        A.  Indeed, indeed, which is a pattern I follow myself on
    19        an audit.
    20
    21   MR. JUSTICE BELL:  Yes, Mr. Morris?
    22
    23   MR. MORRIS:  I do not have any problem with the report.  It is
    24        entitled The Management of Occupational Health & Safety.
    25        That is what it is about, the management systems.
    26
    27   MR. JUSTICE BELL:  I am not inviting comment.  I am inviting you
    28        to continue your cross-examination.  These are all matters
    29        which, if they are thought important, can be argued at the
    30        end of the day.
    31
    32   MR. MORRIS:  Yes.
    33
    34   THE WITNESS:  Have we finished with that?
    35
    36   MR. MORRIS:  I think we have, yes.
    37        A.  I think the reference was 55.
    38
    39   MR. JUSTICE BELL:  Just general information, I have punched my
    40        Successful Health & Safety Management and put it behind
    41        that report so I know where to find it, since the HSE
    42        report refers to and quotes from that document.
    43
    44   MR. MORRIS:  As far as the figures on reported accidents which
    45        is obviously very helpful information, I think we had
    46        better have a look at it at lunch-time or something.  Is it
    47        possible to have that back?
    48
    49   MR. JUSTICE BELL:  Yes.  You are not going to ask about
    50        it  --- 
    51 
    52   MR. MORRIS:  Now. 
    53
    54   MR. JUSTICE BELL:  -- I think it may be wise to have a look at
    55        it over the mid-day adjournment and then ask any further
    56        questions you have about it after lunch.  I have put that
    57        for the time being at the back of tab 41 which is
    58        Mr. Purslow's second statement which he has not adopted but
    59        which does refer to accident rates.  That is the yellow
    60        bundle.

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