Day 060 - 02 Dec 94 - Page 48


     
     1
     2   MS. STEEL:  When did they give you that figure?
     3        A.  When we requested it originally.
     4
     5   Q.   When was that?
     6        A.  We started monitoring recycling in McDonald's around
     7        the mid-80s.  Prior to that we were not aware of exactly
     8        what the recycled content was in our packaging.  We knew it
     9        was going on, but we were not aware of the totals.  Around
    10        the mid-80s we started to monitor it and have monitored it
    11        ever since.
    12
    13   Q.   Right, and how did you monitor it?  Did you keep records of
    14        it?
    15        A.  No, in -- well, we have records, yes, but in meetings
    16        with the suppliers basically.
    17
    18   Q.   So they told you it was 1981 in the mid-80s?
    19        A.  When we first requested the information, yes.
    20
    21   Q.   And you have remembered it ever since?
    22        A.  We have remembered it.  We would hardly forget it,
    23        would we?
    24
    25   Q.   If you did not have this statement open now and I asked you
    26        the dates when different percentages of recycled paper were
    27        brought in, do you think you would remember them all?
    28        A.  No, I do not think so but they are on record in the
    29        Purchasing Department.
    30
    31   Q.   They are on record?
    32        A.  Yes.
    33
    34   Q.   In what form?
    35        A.  In the suppliers' file.
    36
    37   Q.   Right.
    38
    39   MR. JUSTICE BELL:  If you got a paper four hole tray or two hole
    40        tray, does that carry anything but the drink?
    41        A.  Generally, no, it is usually drinks.
    42
    43   Q.   So, suppose I ordered a couple of Cokes and got a two hole
    44        tray and carried that back to my table, what would happen
    45        to the tray then, having carried two drinks 30 feet or
    46        whatever?  Would it be used again or would that go in the
    47        bin?
    48        A.  Generally, it would be disposed of and recycled.
    49
    50   MS. STEEL:  It would be recycled? 
    51        A.  Generally, yes. 
    52 
    53   Q.   Who by?
    54        A.  Well, we try with something as bulky as a two and four
    55        hole tray we try to separate those out because that is
    56        quite a lot of material.
    57
    58   Q.   What, someone fishes them out of the bins?
    59        A.  When the bins are emptied, yes.  In essence, we do not
    60        use a lot of them because, to the Judge's point, in the

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