Day 008 - 07 Jul 94 - Page 39


     
     1        A.  Yes.  It was because we wanted to improve the
              environmental features of our packaging.  We recognised
     2        that there was a scientific issue, a preponderance
              information at that time that in our estimation warranted
     3        review by our management.  We also saw that there were
              alternatives available that were better for the
     4        environment that we could switch to.
 
     5   Q.   By what date, as far as you can say, had the phase out
              been completed?
     6        A.  The phase out in the United States was completed
              during the calendar year of 1988.  When we made our
     7        announcement we said it would take 18 months to complete
              it.  In my role at Perseco, I was in charge of that phase
     8        out and we completed it by the calendar year end 1988.
 
     9   Q.   So, by the beginning of 1989, is it, therefore, right that
              none of the polystyrene foam in use for McDonald's
    10        packaging had been blown by CFC?
              A.  Correct.
    11
         Q.   Was there an extent to which CFCs were at that time during
    12        the phase out replaced by HCFCs?
              A.  Yes.
    13
         Q.   By HCFC-22?
    14        A.  Correct.
 
    15   Q.   Sometimes, or in the form you used it, Perseco used it, or
              their suppliers used it, called Formacel-S?
    16        A.  Yes.
 
    17   Q.   Was there any cost advantage in the exchange of CFC for
              HCFC-22?
    18        A.  No.
 
    19   Q.   At the time when HCFC-22 was introduced as an alternative
              to CFCs, was it introduced for every use -- I have not put
    20        that right -- was it 100 per cent a substitute?
              A.  No, it was not.  Before we made a switch in August
    21        1987, roughly half of our foam packaging was using, had
              always used, hydrocarbons as a blowing agent, so we are
    22        only dealing with half the packaging from the beginning.
              Of that half that we were going to switch out of, a
    23        certain proportion, approximately 50 per cent, actually
              phased into hydrocarbons; the other 50 per cent which
    24        would actually be one quarter of the whole phased into
              HCFC-22.
    25
         Q.   So is the position after the phase out this, that in 
    26        approximate figures 75 per cent was blown by hydrocarbons? 
              A.  That is correct. 
    27
         Q.   And 25 per cent by HCFC-22?
    28        A.  After it was all done.
 
    29   Q.   At the time when HCFC was introduced in a proportion of 25
              per cent, were you conscious -- you were in charge of this
    30        on behalf of Perseco by now, you just told us -- whether
              or not HCFC-22 had any potential damaging effect for the

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