Day 131 - 06 Jun 95 - Page 53

     
     1        something they want to prevent is accidents.  What this
     2        report about is accidents, is it not; and it is true that,
     3        as has been said in the court before, the McDonald's
     4        accident book is, in fact, an injury book; people note
     5        injuries?
     6        A.  That is so.  That is why they have a specific incident
     7        reporting form as well, which includes things other than
     8        injury.
     9
    10   Q.   But that is generally used if someone is off work for three
    11        days, or something like that?
    12        A.  My understanding is that it would be used for other
    13        things as well, but yes.
    14
    15   Q.   So these figures here, say, for example, Heinrich (which
    16        you said is The Bible), 1:29:300?
    17        A.  Yes.  He is talking about the outcome of the same kind
    18        of accident to the same person, and that is the likely
    19        spread of outcome -- emphasising the point that, normally,
    20        if you fall over, you get up, but occasionally somebody is
         going to crack a bone, or whatever it may be.
    22
    23   Q.   So they give a factor of 10 in terms of injuries to actual
    24        accidents; and then the Bird one gives a factor of 10 to
    25        600, a factor of 60, for injuries to accidents?
    26        A.  No.  I am sorry.  The 600 are incidents with no visible
    27        injury or damage; they are near misses, if you like
    28
    29   Q.   I understand.  It is an accident, but it has not resulted
    30        in an injury?
    31        A.  That is right.
    32
    33   Q.   The Tye Pearson one, we have a factor of 50 injuries
    34        requiring first aid to 5 to 400, a factor of 8.  We have a
    35        factor of 10, a factor of 60 and a factor of 8.  Where, in
    36        those sort of learned opinions, would you situate, say, the
    37        McDonald's factor of injuries to accidents that do not
    38        result in injury?   Would you say it is nearer 10 or nearer
    39        60?
    40        A.  Injuries, near misses or near hits, or whatever you may
         call it?
    42
    43   Q.   Yes.
    44        A.  I have really got no idea.  One could speculate.  It is
    45        so difficult, because, I mean, theoretically, if one slips
    46        like that and does not fall over, that is a near miss.
    47        There will be dozens of those every day anywhere, when one
    48        is walking down the street, if one comes to that.  It is
    49        very difficult to speculate.
    50 
    51   MR. JUSTICE BELL:  I must say I have some difficulty with the 
    52        concept of incidents with no visible injury or damage, 
    53        because how you can have reliable figures -- can you have
    54        reliable figures on that?
    55        A.  I do not think you can, my Lord.  This was some effort
    56        to look at it and to suggest that you have to look wider
    57        than just the accidents recorded which one would accept --
    58        than just the injuries which would one would accept.
    59
    60   MR. MORRIS:  Yes.  Because if you want to avoid injuries, you