Day 009 - 08 Jul 94 - Page 40


     
     1   Q.   But in the meantime you are going to continue using
              packaging which damages the environment?
     2        A.  We are going to continue using packaging that serves
              the function of providing the breakfast meal to our
     3        customers and then minimise the environmental impact by
              doing so.
     4
         Q.   What about the foam that is used in Europe and in other
     5        countries, the foam packaging that is used?
              A.  The question?
     6
         Q.   I understood it concerned you that foam was harmful to the
     7        environment and that was why you switched to sandwich
              wraps?
     8        A.  I did not say that.  I said that our switch in the
              United States was based on minimising the environmental
     9        impact, different options, so if could you rephrase your
              question?
    10
         Q.   Do you not want to minimise the environmental impact in
    11        Europe?
              A.  Absolutely.
    12
         Q.   So why have you not switched over to sandwich wraps in
    13        Europe?
              A.  Why have we or have not?
    14
         Q.   Why have you not?
    15        A.  That is a generic statement.  Can you give me one
              country in particular?
    16
         Q.   England.
    17        A.  OK, in England?  First of all, I cannot give you the
              exact answers since I do not run.
    18
         Q.   I thought you oversaw worldwide?
    19        A.  I can give you my perspective on it.
 
    20   MR. JUSTICE BELL:  Does not Mr. Oakley deal with packaging in
              England?
    21
         MR. RAMPTON:  Yes.
    22
         MISS STEEL:  Yes, he does but Mr. Langert did say he oversaw
    23        something about worldwide package and that it was his
              concern to make sure that countries did not keep repeating
    24        the experiments that had gone on previously.
 
    25   MR. JUSTICE BELL:  That may still allow someone knowing more
              with regard to England.  I am just checking more for my 
    26        own benefit that Mr. Oakley is packaging UK, so far as the 
              plaintiffs are concerned, the second plaintiff is 
    27        concerned?
              A.  I will give the answer from my perspective.  The
    28        answer from my perspective is, we made our decision in the
              United States based on very specific packages made by
    29        specific suppliers compared to other packages.  In the
              life cycle study that we did was based on those actual
    30        manufacturing plants, you know, located in the United
              States, the actual source of raw materials, the exact

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