Day 152 - 11 Jul 95 - Page 04
1 A. About that, yes.
2
3 Q. About that, right. Would it be fair to say on average that
4 there would be two of them away per week?
5 A. Probably fair to say that there may be. I would advise
6 the Manager, or, if I was the Manager myself, advise the
7 Manager doing the schedule, perhaps, to build that in. Two
8 people away on holidays would certainly be a wise move to
9 make anyway.
10
11 Q. Right. If you add up the total of the hours, the number of
12 hours, worked to be done according to the schedule?
13 A. Right.
14
15 Q. It comes to 1,170, plus you have just added an extra 19
16 through the Saturday and the Sunday?
17 A. Right.
18
19 Q. Which I have not obviously added in?
20 A. I have not been able to add the figures up, so I would
21 have to be guided by you, certainly.
22
23 Q. Anyone can check them if they want to. I have been fairly
24 careful in adding them up. 28 people working full-time at
25 35 hours a week, and you are saying that it was more common
26 for them to work 39 hours a week, would come to 980 hours
27 which then, with the addition of your 19, would leave
28 around about 210 working hours to be shared out between the
29 part-time employees, in which case they would be lucky if
30 they got eight hours each per week. It must be, must it
31 not, that you actually had a lot of people on the books
32 that were not working every week?
33 A. That is why I was at pains yesterday, I think I asked
34 you about three times, to ensure that you did mean these
35 were people working crew stations. If I might explain to
36 you how the system works, perhaps, then I can give you an
37 idea how I come to the 100 in my own mind?
38
39 MR. JUSTICE BELL: I think you should, yes.
40 A. The best way I can approach that is if I was going to
41 be speaking to you as a new Manager doing the schedule,
42 looking at your hiring requirements. A first premise is to
43 take Monday to Friday and just for argument sake, let us
44 say that your full-timers will only work Monday to Friday
45 and I will give them the weekend off, just to start off
46 with. What you would do then is to see the maximum number
47 of people for the day shift and the maximum number of
48 people for the night shift. So in this case 14 and 12 is
49 the 28 -- I think you mentioned that figure as well. That
50 is 28 people full-time.
51
52 I would then look at Saturday and Sunday and say again, for
53 simplicity sake, let us assume they have been worked by
54 part-timers, I would take the 25 and the 12 to give me 37
55 and add on the 15, and that gives me about 52 people.
56
57 Q. Sorry?
58 A. So, take 25 available Saturday lunch-time, 12 available
59 in the evening, 15 for the Sunday, would give me 52
60 part-time people and 28 full-time. That is first base, so