Day 131 - 06 Jun 95 - Page 44


     
     1   MR. JUSTICE BELL:  -- he thinks, in effect, he had become
     2        McDonald's outside consultant in relation to health and
     3        safety matters, not being food safety?  Is that really what
     4        you are asking?
     5
     6   MR. MORRIS:  Yes.  (To the witness)  When was the first time --
     7        well, I think we have established that it sort of began
     8        somewhere in the late 1990s.  But I am trying to find out
     9        the first time McDonald's was asking you: "What do you
    10        think of our safety systems?  What do you think of our
    11        safety culture?"
    12        A.  From the time I came in, effectively, because Jill was
    13        developing a department, she was casting around to see if
    14        that was the best model, and so on and so forth.  Even if
    15        I was not actually making, I do not know, a full day's
    16        input, she would phone me up and ask my opinion, or would
    17        fire a document across to me and ask for comments, that
    18        sort of thing.  So it just began to develop from there.  It
    19        would be difficult for me to say exactly what I did and
    20        when, and so on.
    21
    22   Q.   So sometime in the first few months that you were engaged
    23        by Jill Barnes, you began to be asked things about the
    24        entire setup of McDonald's with regard to safety?
    25        A.  Yes.  I mean, in fairness, you would have to do that if
    26        you are doing, for instance, a COSHH assessment, because
    27        you cannot just look at chemicals in isolation; you have to
    28        ask yourself how the chemicals are used, and so on and so
    29        forth, so you begin to get to know the operation right from
    30        Day One, basically.
    31
    32   Q.   We will come back to that in a minute.  Before we look at
    33        the specifics with McDonald's, in the catering industry,
    34        are you aware of something called Statistical Review of the
    35        Hotel and Catering Industry, published by the
    36        Catering Intelligence Unit?
    37        A.  No, I am not.
    38
    39   Q.   In association with the industry's training board, back in
    40        1982?
    41        A.  I have never heard of the Catering Intelligence Unit.
    42
    43   Q.   What figures would you say are employed in the hotel and
    44        catering industry, in general, in this country, what kind
    45        of numbers?
    46        A.  I am sorry, the number of people who are employed?
    47
    48   Q.   In the whole catering industry, hotel and catering
    49        industry.
    50        A.  I am honestly not sure.  It is -- certainly it is one 
    51        of the major employers.  It is certainly over a million, 
    52        but I would not be aware of the exact figure.  Can you 
    53        produce it for me?
    54
    55   Q.   Would you say it was somewhere -- a rule of thumb could be
    56        something around two million?
    57        A.  I would say that was probably somewhere around right,
    58        but -----
    59
    60   Q.   McDonald's have given figures earlier on in the case, by

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