Day 131 - 06 Jun 95 - Page 11

     
     1        surrender one of their copies, then you or his Lordship can
     2        have one in front of you.
     3
     4   MR. JUSTICE BELL:  What are we going to do about this?
     5
     6   MR. MORRIS:  We have a fair copy.
     7
     8   MS. STEEL:  If we can have it back?
     9
    10   MR. JUSTICE BELL:  Is it likely that you will be putting parts
    11        of this to Mr. Purslow in cross-examination; have you that
    12        in mind or not?
    13
    14   MR. MORRIS:  It is possible, yes; not a great deal, though.
    15
    16   MR. JUSTICE BELL:  What I ask you consider is, if there is an
    17        introduction or a summary of some kind, perhaps that could
    18        be photocopied in due course, and any parts which are put
    19        to Mr. Purslow in due course.
    20
    MR. RAMPTON:  I do believe, my Lord, it may be more sensible for
    22        us to get some more copies, if we can.  HMSO is only just
    23        up the road.  We will try to do that today.
    24
    25   MR. JUSTICE BELL:  If you do that, then I will have my own
    26        copy.  If that is not done, I will borrow a copy for a week
    27        or so at some stage.
    28
    29   MR. RAMPTON: (To the witness)  Could you turn to page 48,
    30        please?
    31        A.  Yes, I have it.
    32
    33   Q.   I would like you to look at the first paragraph on
    34        page 48.  I will read it out.  It is under the
    35        heading "Measuring Performance":
    36
    37        "A low accident rate, even over a period of years, is no
    38        guarantee that risks are being effectively controlled and
    39        will not lead to injuries, ill-health or loss in the
    40        future.  This is particularly so in organisations where
         there is a low probability of accidents but where major
    42        hazards are present.  In such cases, the historical
    43        incidence of reported accidents can be an unreliable
    44        deceptive indicator of safety performance.  In order to
    45        ensure that an organisation's policy is effectively
    46        implemented, the steps taken to develop a positive health
    47        and safety culture and to control risks need to be
    48        measured."
    49
    50        First, Mr. Purslow, do you see anything in this paragraph 
    51        with which you, personally, would disagree as an expert? 
    52        A.  No, not at all. 
    53
    54   Q.   Second, so far as your experience of McDonald's is
    55        concerned, how do they fit into that paragraph?
    56        A.  Well, they use their reportable accident rate as a
    57        general indicator, but the main work comes through things
    58        like safety audits in stores and their full store audits,
    59        and so on and so forth, which is aimed at measuring the
    60        effectiveness of their systems.  That, to me, is entirely