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.