Day 136 - 16 Jun 95 - Page 04

     
     1        One sees, Mr. Brown, that the document is dated 25th August
     2        1992 and that it is subheaded:  "Re.  K35 retrofit
     3        programme".  First of all, what is "K35"?
     4        A.  K35 is the name given to material called Altro flooring
     5        and it is a safety flooring.  The "K" stands for kitchen
     6        and Altro recommends it to be used in kitchen areas.
     7
     8   Q.   So is this is a code for a particular kind of Altro, is it?
     9        A.  Yes, it is a safety flooring.
    10
    11   Q.   What is a retrofit?  I think we know, but please tell us?
    12        A.  It is where we go back into an existing restaurant and
    13        put in a new material.  It could be a flooring, it could be
    14        a wall fit, wall vinyl, it could be ceiling tiles, it could
    15        be light fitting.
    16
    17   Q.   We see here that it calls itself "programme" and it says,
    18        "proposed" with 11 different locations underneath that; do
    19        you see that?
    20        A.  That is correct, yes.
    21
    22   Q.   We see that the last of those locations is Epsom?
    23        A.  Yes.
    24
    25   Q.   The dates given are 14th and 15th October 1992?
    26        A.  That is correct.
    27
    28   Q.   Do you happen to know whether or not that retrofit was
    29        carried out at that time, October 1992, at Epsom?
    30        A.  It was carried out.
    31
    32   Q.   It was.  Can you tell me this, please?  What was the last
    33        occasion before October 1992 when Epsom floors, kitchen
    34        floors, were the subject of a retrofit?
    35        A.  In February of 1988 we refurbished the whole restaurant
    36        and, as part of that refurbishment, we actually retrofitted
    37        the floor tiles in the kitchen area.
    38
    39   Q.   What did you put into the kitchen?
    40        A.  We put a non-slip tile.
    41
    42   Q.   Not Altro?
    43        A.  Not Altro; a non-slip tile in the areas where we
    44        normally specify them to be laid.
    45
    46   Q.   Are you conscious, as we have heard in this court, that
    47        nearly 50 per cent of the accidents which happen to the
    48        crew in the restaurants are caused by slips and falls?
    49        A.  Yes.
    50 
    51   Q.   So, I expect this is not a problem, the qualities of the 
    52        flooring in the kitchen area are of importance? 
    53        A.  They are.
    54
    55   Q.   My Lord -- this may lighten a Friday morning -- Mr. Brown,
    56        at his own suggestion, has brought with him to court some
    57        samples of different kinds of flooring that McDonald's have
    58        used that your Lordship may wish to see.  I can see what
    59        one of them is because it has the name on it.  Before
    60        I hand them up for the witness to identify and then the