Day 132 - 07 Jun 95 - Page 09

     
     1
     2   Q.   -- and there being no reference to burns in it?
     3        A.  Yes.
     4
     5   Q.   You made an answer to the effect that it is obvious that if
     6        you put your hand on a hot surface you will burn yourself?
     7        A.  Indeed.
     8
     9   Q.   So you, in effect, expect people to appreciate that, but
    10        if, on the other hand, there is a slippery floor so that
    11        they might slip and inadvertently put their hand on or in
    12        something hot, then that is something that you -----
    13        A.  Indeed, that one would actually actively look for.  One
    14        of the points I was making, my Lord, is that the burn is
    15        the result of the accident, and so one looks for preventing
    16        what I think of as non-standard behaviour which may result
    17        in a burn.
    18
    19   Q.   That is what I understood you to be saying, in effect.  If
    20        you look at page 852 -- that is the bundle page --
         para. 339:  "The following are examples of where
    22        performance standards did not exist, were inadequate or not
    23        expressed as a performance standard"?
    24        A.  Yes.
    25
    26   Q.   The third is preventing burns in the kitchen.
    27        A.  Yes, indeed.
    28
    29   Q.   Do you have a view on what the Unit had in mind there, what
    30        they were expecting there, with regard to preventing burns
    31        in the kitchen by performance standards?
    32        A.  I do not, my Lord.  I am not quite sure what they were
    33        getting at.  I mean, I can see the comment in that, as has
    34        been pointed out, burns are a frequent occurrence as a
    35        result of, as I say, an accident or whatever.  But I am not
    36        quite sure what standard they would expect to lay down to
    37        prevent burns in the kitchen.
    38
    39        My contention would be that the training and the
    40        application of systems to do a job in a particular way in
         itself is intended to prevent such non-standard accidents
    42        which result in burns.
    43
    44   MR. JUSTICE BELL:  Yes, thank you.
    45
    46             Cross-examined by the Defendants, continued.
    47
    48   MR. MORRIS:  As you said, this is a report about systems, is it
    49        not?
    50        A.  Essentially, yes. 
    51 
    52   Q.   They say about hustle -- I cannot remember what they said 
    53        about it -- at the beginning of their second hustle, on
    54        page 829:  "It provides a good illustration of the culture
    55        in the Company and the importance of good communication in
    56        the organisation"?
    57        A.  Yes.
    58
    59   Q.   Therefore, hustle would relate to an illustration of the
    60        culture in the Company, so it would be relevant, would it