Day 132 - 07 Jun 95 - Page 10


     
     1        not, in terms of systems?
     2        A.  Yes.
     3
     4   Q.   And the approach of the Company?
     5        A.  Yes.
     6
     7   Q.   Yes, and they felt -----
     8        A.  They felt that the definition of speed and efficiency
     9        was the sort of thing that McDonald's fostered which
    10        I think would ----
    11
    12   Q.   Right.  Going back to page 852, their brief would not have
    13        been to analyse each job, would it, and evaluate each
    14        particular task to see whether that particular task or that
    15        particular timing allowed for each task was competent or
    16        whatever; they were looking at systems, were they not?
    17        A.  Yes, but you can only look at systems by looking at the
    18        operation of cooking.  If you are looking to see whether
    19        the systems that keep a kitchen safe are working in
    20        practice, you have to observe that kitchen in operation,
    21        then you can move from -- what the HSE do, and during an
    22        audit -- you move from the specific observation to the
    23        general point.  So you use the specific observation to
    24        say:  "In that case we need a system to control that
    25        non-standard action".
    26
    27   Q.   Yes, but they were not analysing, they were not doing a
    28        comprehensive review of each McDonald's job and job
    29        description and time allotted?
    30        A.  Indeed not.  All I am saying is they would have
    31        observed most of the jobs being done and, obviously, to
    32        make these sorts of comments about performance standards
    33        being required, they must have observed those to say these
    34        standards needed making.
    35
    36   Q.   That is exactly what I was going to say, that although the
    37        entire report is about systems and hustle being a
    38        particular aspect of the systems, it does choose to mention
    39        852 in passing examples of where performance standards did
    40        not exist.  In other words, these were things that they
    41        noticed in a fairly non-systematic way that were worthy of
    42        comment?
    43        A.  I am sure they would not agree with your statement of
    44        in a "non-systematic way".  One does not do a
    45        non-systematic audit.  If that is what the HSE felt were
    46        missing, they were missing that, and I would not argue with
    47        that for one second.   But they would have done that
    48        after  -----
    49
    50   Q.   But they are examples, are they not? 
    51        A.  I cannot say that.  I did not conclude the audit. 
    52 
    53   Q.   It says there -----
    54        A.  What I am saying -- if I may finish -- is that they
    55        would have highlighted these things after a comprehensive
    56        trawl through the procedures that McDonald's had written.
    57        They have highlighted these things as needing attention.
    58        I would have expected the list to be more or less
    59        comprehensive.  These men are professionals.  When they do
    60        an audit they do it thoroughly, believe you me.

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