Day 131 - 06 Jun 95 - Page 47
1 statistical basis.
2
3 Q. They might be temporary jobs, in that case?
4 A. There are temporary jobs, certainly; and sometimes you
5 work twilight shifts and all sorts of things in
6 manufacturing. I am not quite sure of the statistical
7 basis of the HSE figures. I am quoting their figure that
8 they publish nationally.
9
10 Q. But the bulk of food manufacturing factory work is going to
11 be a standard 40 hour week, something like that?
12 A. I would have thought so, yes.
13
14 Q. Whereas the bulk of McDonald's, as we have heard,
15 80 per cent of their staff are part-time, something around
16 20 hours a week?
17 A. I think the figure was 80 per cent work less than
18 39 hours a week. Now, many factories do, too. I am not
19 sure of the breakdown of the two, to be perfectly honest.
20
21 Q. As far as I understand from evidence that has been given in
22 this court, it is something like an average of 20 hours a
23 week for 80 per cent of McDonald's staff. That can be
24 checked.
25 A. I will take your word for it.
26
27 Q. So, in order to weigh your figure of 12 per 1,000 at
28 McDonald's with the 31 per 1,000 at the food manufacturing,
29 we would have to double the 12 per 1,000 if that is based
30 upon people working half the number of hours?
31 A. Yes. If we accept that McDonald's report 85 to 90
32 per cent of their reportable accidents, we will also have
33 to multiply the figure for the food industry by three,
34 because there is supposed to be an under-reporting by a
35 factor of one in three in industry generally. So if we are
36 going like-for-like, we have to do it like that, and it
37 becomes something 24 to 90, rather than 12 to 31.
38
39 Q. We can go on to that then. The McDonald's reporting
40 rate -----
41
42 MR. JUSTICE BELL: Sorry -- rather than 12 to 31, you mean?
43 A. Yes. If we compare -----
44
45 Q. Yes. I understand what you mean. One can do the precise
46 arithmetic.
47 A. Absolutely, yes. It is that sort of scale.
48
49 MR. MORRIS: The catering sector, as a whole, you said you have
50 had discussions about this, about reporting to local
51 authorities, and whatever?
52 A. Yes.
53
54 Q. But the catering sector as a whole has very specific
55 accidents associated with it; kitchen work has very
56 specific accidents associated with it; yes?
57 A. The bulk of accidents would fall within three or four
58 categories, certainly; but, obviously, like any workplace,
59 you can get a whole spread of accidents.
60
