Day 007 - 06 Jul 94 - Page 89


     
     1        percentage of McDonald's packaging in the USA still
              consists of polystyrene foam?
     2        A.  I would have to look into the tables.
 
     3   Q.   Could you do a little bit of research for us back in
              America, send us a letter from America giving us a figure?
     4        A.  Yes.
 
     5   MR. JUSTICE BELL:  If you do that, if you identify the sources
              in the tables we have, then we can see whether they can be
     6        validated or not for ourselves.
              A. There is a 1992 table in here I could use.
     7
         MR. RAMPTON:  Where do we find that?
     8        A.  Tab 50.
 
     9   Q.   Page 50?
              A.  Page 50, I am sorry, of page 3.
    10
         Q.   Yes.
    11        A.  All plastic packaging is 16 per cent -- here we go, it
              is in there:  Foam hot cups and bowls was approximately 2
    12        per cent; foam breakfast packaging was approximately one
              and a half per cent; so some 4 per cent at the most.
    13
         Q.   That was in 1992?
    14        A.  That was in 1992 subsequent to our sandwich foam phase
              out.
    15
         Q.   So about 4 per cent in 1992?
    16        A.  Yes.
 
    17   Q.   While you are on that page----
 
    18   MISS STEEL:  Could I just clarify something, sorry, I thought
              you said earlier that hot cups were foam as well?
    19        A.  The first one is hot and cold cup lids, so the lids
              are just rigid plastic.
    20
         MR. RAMPTON:  We find foam hot cups specified half way down the
    21        column.  We find foam packaging and foam plates.  Is there
              anything else in that list which is made of polystyrene
    22        foam?
              A.  No, sir.
    23
         Q.   While we have that page open, do you see the figure in the
    24        top half of the table 181,639?
              A.  Yes.
    25
         Q.   Which is the figure total weight -- sorry, ton weight of 
    26        paper used for that year? 
              A.  Yes. 
    27
         Q.   That does not or does it tell me, does that include any
    28        corrugated material?
              A.  No, it does not.
    29
         Q.   One final question just so we do not have to look back at
    30        the tables, is my memory correct that in those tables
              showing the locations of the paper mills which your

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