Day 152 - 11 Jul 95 - Page 18

     
     1
     2   MR. JUSTICE BELL:  Right.  1,189; let us say 1,190; I think
     3        someone ought to check it because I am sure Ms. Steel has
     4        done her best and she is probably right, but we all make
     5        mistakes with our arithmetic every now and again.
     6
     7   MS. STEEL:  I am happy for anyone to check it.
     8
     9   MR. JUSTICE BELL:  Let us suppose Ms. Steel is right for a
    10        moment.  You have 1,190 hours?
    11        A.  Yes, sir.
    12
    13   Q.   All the year round you have 26 people full-time; you may
    14        get a week when people are ill but if there are 28 and two
    15        are on holiday you are left with 26.
    16        A.  Well, no, sir.  That is where ----
    17
    18   Q.   Right.  You say that, so explain why not.
    19        A.  That is because when I started part of this discussion
    20        I said let us assume certain things.  Let us assume that
         Monday to Friday we only have part-timers.
    22
    23   Q.   I am not interested in you assuming things.  I thought you
    24        were telling me that there would be 28 at Leicester
    25        full-time, using that to help jog your memory?
    26        A.  Yes, to jog my memory but, in terms of trying to find
    27        out -- I may well need on a Friday night 8 till 9 twelve
    28        people, but they could all be part-timers.
    29
    30   Q.   I appreciate that.
    31        A.  So, therefore, I may only need 14 full-timers if they
    32        only work the day shifts.  I am not saying these are
    33        figures that I would hold my hand up to say they are a true
    34        reflection.  It is the idea of saying, does that -- in
    35        terms of going backwards and looking at how many is on the
    36        payroll I would say then that a hundred payroll people had
    37        a 70/30 split would work on this sort of crewing levels.
    38
    39   Q.   If you take off five non-stations and it is a 70/30 split
    40        you are left with 25 full-timers on station or available to
         go on station?
    42        A.  Yes.
    43
    44   Q.   Two of those are going to be on holiday, let us say, at any
    45        given time; so you have 23 available to be on station?
    46        A.  Right.
    47
    48   Q.   Let us suppose they work an average of 37 hours a week,
    49        somewhere between the 35 and 39; that is 850, let us say,
    50        hours per week? 
    51        A.  Full-time hours? 
    52 
    53   Q.   Yes.
    54        A.  Yes.
    55
    56   Q.   This is all hypothetical.
    57        A.  Certainly.
    58
    59   Q.   That leaves you with 340 hours a week for your part-timers
    60        if you have 1,190 hours.  So 1,190 less 850.  If you have