Day 131 - 06 Jun 95 - Page 58


     
     1        A.  Yes.
     2
     3   Q.   You have seen or heard of no estimate of what it was
     4        previous to that?
     5        A.  No, I have not.
     6
     7   Q.   You said that the RIDDOR accident statistics are valuable
     8        in terms of identifying trends?
     9        A.  Yes.  They are but one part of the picture, but they
    10        identify trends, certainly.
    11
    12   Q.   So why did McDonald's not compile statistics before your
    13        time?  Did you ask them?
    14        A.  I have never asked them.  Many organisations did not
    15        compile statistics before then.  They have to get their
    16        reporting right before they become meaningful.
    17
    18   Q.   They were not compiling statistics when you joined
    19        McDonald's, when you started to be used by McDonald's ---
    20        A.  Well, that is not the first -----
    21
    22   Q.   -- engaged?
    23        A.  That is not the first question I ask when I walk into a
    24        company:  "Show me your statistics".  If you say that is
    25        the case, I am sure that is so.  But the whole point was,
    26        I was asked to begin to contribute to their safety
    27        management systems which they have continued to build up
    28        from then onwards.  But, certainly, they had a lot of
    29        things in place before I walked in the door.
    30
    31   MR. JUSTICE BELL:  Do you want to take the five-minute break
    32        now?
    33
    34   MR. MORRIS:  Yes.
    35
    36                            (Short Adjournment)
    37
    38   MR. MORRIS:  To save time, you cannot offer an expert opinion on
    39        what happened before you joined the Company?
    40        A.  No.  I can tell you the condition when I came in, but
    41        I cannot say what had happened before.
    42
    43   Q.   You cannot give an expert opinion of what actually happens
    44        in the stores on a day-to-day basis?
    45        A.  Yes, I can, because I have observed what happens in the
    46        stores on a day-to-day basis.
    47
    48   Q.   You said you watched for two hours some unit, but in terms
    49        of -----
    50        A.  On a number of occasions, and I have obviously visited 
    51        stores. 
    52 
    53   Q.   How many occasions have you visited stores and observed for
    54        a significant period of time?
    55        A.  It would be difficult to say.  Probably a dozen
    56        occasions, something like that.  I have been in on many
    57        occasions, because I tend to meet people there, or
    58        whatever.  I have to say that when I take my son for a
    59        burger, or whatever, I cannot stop looking.  So I do
    60        genuinely feel that I know what goes on in the norm.

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