Day 008 - 07 Jul 94 - Page 48


     
     1        our use of recycled paper.  So that is why I think Dave's
              numbers are more exacting after that.
     2
         Q.   Can I please, for his Lordship's benefit -- I will not ask
     3        you to do what you call the maths now -- just ask you to
              look at a couple of documents?  If you could, in that
     4        bundle which, I think, the pink IV, which has the EDF
              document, turn on to tab 10, keeping your finger in the
     5        EDF document for the moment, please?
              A.  Yes, OK.
     6
         Q.   Have you got to tab 10?
     7        A.  Yes.
 
     8   Q.   We see here:  "Material discarded into the municipal solid
              waste stream.  McDonald's quantified total materials
     9        purchased in 1988."   That was a time when you were at
              Perseco or might have been?
    10        A.  Halfway.
 
    11   Q.   You were at Perseco but you were not necessarily in your
              place as chief environmental person?
    12        A.  I was in the mid 1988 and when his report would have
              been done it would have been done the following year in
    13        order to quantify it.
 
    14   Q.   Would you think you would have and had an input into this
              document?
    15        A.  Yes, I would have created that document, or Dave would
              have done that perhaps.
    16
         Q.   If you look at the bottom of the document, you see direct
    17        food packaging paper?
              A.  Yes.
    18
         Q.   That seems to be what is used at the counter, is it, in
    19        the restaurant; is that right or not?
              A.  Yes, as defined here it would be the consumer
    20        packaging.
 
    21   Q.   The total paper is given as 162,877 United States American
              tonnes, right?
    22        A.  Yes.
 
    23   Q.   Keeping that figure in our heads, this is for 1988?
              A.  Can I add one other thing to this?
    24
         Q.   Yes.
    25        A.  I want to highlight the number for pulp trays that
              I referred to since we have the report out. 
    26 
         Q.   The? 
    27        A.  The 1988 report that shows, within that list of direct
              food paper packaging there is a line in the middle that
    28        says "pulp trays", 10,163 tonnes.  If you look towards the
              McDonald's paper packaging consumption chart -----
    29
         MR. JUSTICE BELL:  Which page is that?
    30        A.  Which is page 349.
 

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