Day 169 - 04 Oct 95 - Page 13


     
     1
     2   Q.   And they all kept leaking?
     3        A.  Occasionally they leaked, occasionally they did not
     4        leak, occasionally, they would not go back along the guide
     5        runners because they were banged out of shape, but we have
     6        a maintenance repair man in the store and we also have a
     7        maintenance and repair and reinvestment budget.
     8
     9   Q.   Do these grease troughs have seams along them then?
    10        A.  They have seams at the corners.  I think they are made
    11        out of about eight different pieces of stainless steel.
    12        There is a welded seam at each corner.
    13
    14   Q.   Every night the crew had to take the grills out and clean
    15        behind the grills where this mess was?
    16        A.  Well, they cleaned behind the grills every night anyway
    17        as a matter of course.  If there was mess on the floor
    18        obviously they would clear the mess on the floor up as a
    19        result of the grease trap.  There may well be items on the
    20        floor, say, cups from the front counter and such like, and
    21        you do get a slight grease build up, which is why you clean
    22        it each night anyway.
    23
    24   Q.   Obviously, if crew have to go behind there to clean it up,
    25        there is a risk that they could slip on it?
    26        A.  If they did not see it, yes -- it being brown on a pure
    27        white floor, yes.
    28
    29   Q.   Did you frequently see the crew dropping these grease
    30        troughs on the floor?
    31        A.  They did not always drop them.  Occasionally, they
    32        would, they would stack three or four of them together and
    33        perhaps bang them as they were moving them in and out of
    34        the back room sink as they were spraying them off.
    35
    36   Q.   So they were not a very robust design?
    37        A.  They are quite a robust design, yes, but you are
    38        putting a stainless steel trough between two heavy metal
    39        grills, and it requires a level of precision with the guide
    40        rail that is quite high.  If you bang any part of the guide
    41        rail out of true, then it will not fit in properly.
    42
    43   Q.   You do not know whether other stores were having this
    44        problem or not?
    45        A.  No, I have said that Managers from other stores have
    46        mentioned this problem, but I cannot actually comment on
    47        the problem itself because I have not actually worked in
    48        another restaurant for any significant period of time.
    49
    50   Q.   So the Head Office did not recommend that you all switched 
    51        over to another design that did not have this problem? 
    52        A.  I have no idea.  We spoke to our Supervisor about it, 
    53        certainly, since he began to enquire where we were buying
    54        new ones.
    55
    56   Q.   After how long?
    57        A.  I cannot remember the specific amount of time.
    58
    59   Q.   It was quite some period of time though?
    60        A.  I mean, he asked generally if we have any problems with

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