Day 008 - 07 Jul 94 - Page 47


     
     1        yellow volume III?
              A.  Yes.
     2
         Q.   Right at the back of the bundle, we should call it a file
     3        or binder, in tab 4, divider 4, at page 349, I expect you
              remember this from yesterday because you were in court?
     4        A.  Yes.
 
     5   Q.   We went through it yesterday, but I would like to ask you
              some questions about it, if I may.  For the year 1991, the
     6        year during which this executive summary was produced,
              Mr. Kouchoukos calculated that of all the total paper used
     7        for McDonald's packaging during 1991, the recycled content
              was 51 per cent?
     8        A.  Correct.
 
     9   Q.   Is that so far as you are aware, correct?
              A.  Yes.
    10
         Q.   Have a look at the figure for 1989 where he gives 7 per
    11        cent?
              A.  Yes.
    12
         Q.   Is that correct?
    13        A.  No, that does not give the complete picture.
 
    14   Q.   Why is that?
              A.  I cannot speak for what Mr. Kouchoukos did in this
    15        report.  But what I do believe he did is that he only
              quantified the package that was made with 100 per cent
    16        recycled material, because I was baffled yesterday when he
              was presenting his evidence because it was not accurate in
    17        my own mind.  I reviewed the data and I saw that what he
              did, the number that he pulled in there for recycled
    18        materials, was all the pulp trays, the carry-out trays,
              for drinks.  It is the exact number.  That has always
    19        (since my memory) been made basically with 100 per cent
              recycled paper.  That is the only item he put in there.
    20
         Q.   For 1989?
    21        A.  For 1989 when, in fact, in 1989, as he testified
              yesterday, we were using it for portions, not for all of
    22        our packaging, for portions of the half-meal cartons,
              portions of napkins, and also portions of toilet tissue
    23        and tissue products.
 
    24        I would also like to explain the quantification process
              that we have gone through at McDonald's, if I can.  We
    25        started our official mid-recycle programme in April 1990.
              This was a very major announcement that McDonald's made. 
    26        It was a very formal, very public, commitment.  We 
              announced, basically to the whole of the USA population 
    27        that we are starting mid-recycle USA.  We announced in
              big, bold headlines in advertisements that we want to
    28        spend $100 million a year on recycled materials  of all
              kinds, not only paper but into the construction of the
    29        equipment in our restaurants.
 
    30        As a result of this major initiative of McDonald's we
              began very complicated and thorough efforts to quantify

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