Day 007 - 06 Jul 94 - Page 86


     
     1   Q.   National Bureau of Standards?
              A.  Yes, "that did experimentation on house fires looking
     2        for X and Y".   It caught me off guard because the
              regulations we looked for for food packaging are from our
     3        FDA, and that is the usually the sole regulating group.
 
     4   Q.   Right.  I do not think we need to trouble because
              obviously Mr. Kouchoukos does not know the details of that
     5        report, so  .....
 
     6   MR. JUSTICE BELL:  No.
 
     7   MR. MORRIS:  You also made a point about the 1.3 billion cubic
              feet.  I do not know if we need to go into that.  I do not
     8        know if the figures have been disclosed on the total
              volume of foam in food packaging?  Have they been
     9        disclosed in the case?  I do not know.  I cannot recall
              them having been disclosed.
    10        A.  My calculation and the initial accusation that I saw
              of years ago was 1.6 billion cubic feet.  I did a
    11        calculation based on the weight or the density of our
              average foam being somewhere in the neighbourhood of three
    12        pounds per cubic foot, which is liberal.  It is more like
              four or five pounds, but if I go lower density, it makes
    13        more volume, and my calculation came out with about 25
              million cubic feet.
    14
         Q.   That would be for solid packaging, yes?
    15        A.  That would be for?
 
    16   Q.   If it was in solid form?
              A.  That would be in the sheets that were used to make the
    17        package.
 
    18   MR. JUSTICE BELL:  That is the sheets before it is pressed into
              shape, presumably?
    19
         MR. MORRIS:  Yes.  We do not know until Mr. Lipsett comes
    20        whether he means, for example, if it is just in some kind
              of waste form before being crushed up?
    21        A.  You would have to assume that if the package was in
              its set up form that any amount of weight would collapse
    22        the form and you would get back to the sheet, essentially.
 
    23   MR. JUSTICE BELL:  You have the same volume and weight of
              actual polystyrene, however it is?
    24        A.  That is correct or the same weight certainly.
 
    25   MR. RAMPTON:  My Lord, the total weight of plastic based
              packaging from which, of course, given a norm, one can 
    26        calculate the volume, is given at page 358 of that yellow 
              bundle III -- sorry, pink bundle IV.  That is for the year 
    27        1992.
 
    28   MR. MORRIS:  I think you said though that polystyrene waste in
              landfills helps to aerate landfills?
    29        A.  No, I never made any statement about polystyrene----
         .
    30   Q.   It may have been someone else.
 

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