Day 131 - 06 Jun 95 - Page 45

     
     1        Mr. Fairgrieve from their Marketing Department, that the
     2        quick service restaurant sector of the hotel and catering
     3        industry would be something like 50 per cent -- sorry,
     4        no -- 50 per cent of the meals eaten in the catering
     5        sector, hotel and catering sector, in general, would be
     6        down to the quick service restaurant sector of that --
     7        well, just take my word for it.
     8        A.  If you say so.  It is not something I have any specific
     9        knowledge of.
    10
    11   Q.   But in terms of employment figures, do you happen to know
    12        roughly what the percentage of the whole of the hotel and
    13        catering industry would be in terms of employment down to
    14        the quick service restaurant?
    15        A.  I have got no idea.
    16
    17   Q.   In your opinion, the meals volume to staff ratio, would it
    18        in general be in the quick service restaurant sector and,
    19        certainly for McDonald's, the ratio would be that the
    20        actual meals per employee would be much greater in that
         sense?
    22
    23   MR. JUSTICE BELL:  It must be, must it not?  You are eating a
    24        meal in 20 minutes.  At what someone has called "a white
    25        tablecloth restaurant", it may take you between one and two
    26        hours?
    27        A.  I would have thought so.
    28
    29   Q.   Does "hotel industry" include people changing beds and
    30        things, or is it those who are providing food?
    31        A.  I am not sure of the basis of the statistic, my Lord.
    32        I have not seen the statistics.
    33
    34   Q.   Would you include in that as well -- chambermaids and
    35        doormen?
    36        A.  I presume these are supposed to be the food industry,
    37        catering industry.
    38
    39   MR. JUSTICE BELL:  Anyway, the answer to your question must be
    40        "yes".
    41
    42   MR. MORRIS:  They are catering workers, but it does not
    43        specifically give exact figures.  It came up with a
    44        two million figure as well.  This was 10 years ago.  The
    45        HSE statistics which you relied upon of 31 per 1,000 in
    46        food manufacturing?
    47        A.  It is in that area, yes.
    48
    49   Q.   I would say that if the Plaintiffs have access, power,
    50        possession or control or influence over that document, it 
    51        should be disclosed as an expert reference which will help 
    52        us greatly. 
    53        A.  I believe we are attempting to find the document, even
    54        as I speak.
    55
    56   Q.   Thanks a lot.  That is the HSE annual report, and also the
    57        HSE Recipe for Safety report?
    58        A.  Indeed.
    59
    60   MR. JUSTICE BELL:   If you have a problem with your notes, get