Day 293 - 04 Nov 96 - Page 17
1 Multiplying that by 20,000 stores worldwide, what they have
2 now, something less before, and multiplying it by 364 days
3 of the year, it would be something like a thousand million
4 pounds of waste a year, possibly double if it does not
5 include take-out. It may even be greater in terms of if
6 there is other waste which is not considered. So we are
7 talking about substantial amounts of packaging waste.
8
9 MR. JUSTICE BELL: In very broad figures, since there are
10 roughly 1,000 pounds in half a tonne - it is a bit more -
11 there are 2,240 pounds in a tonne, are there not? It is
12 112 pounds a hundredweight. Twenty hundredweights in a
13 tonne.
14
15 MR. MORRIS: Something like half a million tonnes, sort of
16 minimum, multiplied by whatever percentage of packaging
17 waste may be left out of the calculation from each store.
18
19 MR. JUSTICE BELL: Yes.
20
21 MR. MORRIS: (Pause) Sorry, I am just collecting my thoughts
22 here. In paragraph 11.... Well, there was some confusion
23 between Mr. Kouchoucos and Mr. Langert which I could not
24 get to the bottom of, over what percentage of paper was
25 recycled in 1989 which we had been originally informed,
26 I think, was 7 percent.
27
28 MR. RAMPTON: My Lord, can I intervene here, because it does
29 make things a bit shorter. In consequence of that
30 confusion, and I agree there was a confusion between the
31 two of them, we got, if your Lordship remembers, a
32 Civil Evidence Act statement from Mr. Kouchoucos. I think
33 it is in file yellow 12. The Defendants have agreed the
34 figures which he attaches at appendix 5 to that statement.
35
36 MR. MORRIS: We never agreed any figures.
37
38 MR. RAMPTON: We wrote to the Defendants about it a long time
39 ago. Eventually Mr. Morris responded and that was one of
40 the many documents that he agreed.
41
42 MR. MORRIS: No, we said subject to any cross-examination or
43 dispute during the course of the court case. We were not
44 accepting at face value any document which had been
45 specifically questioned or challenged.
46
47 MR. JUSTICE BELL: What do you say -----
48
49 MR. MORRIS: So do not assume that any document is
50 automatically -----
51
52 MR. JUSTICE BELL: What do you say the net result of it was,
53 anyway?
54
55 MR. MORRIS: The result of it is that I think you should look
56 very carefully at the situation, because we are quite
57 prepared to accept that the maximum recycled content was
58 what Mr. Kouchoucos was stating, 7 percent.
59
60 MR. JUSTICE BELL: 7 percent?
