Day 008 - 07 Jul 94 - Page 40


     
     1        environment, for the ozone layer?
              A.  Yes, we were.  We were conscious from the very
     2        beginning of making our decision that the improvement we
              were making based on the science that we knew at the time
     3        was a 95 per cent improvement in ozone depletion
              potential.
     4
         Q.   So far as you know, were there other large users of
     5        polystyrene foam in the catering industry making the same
              sort of decision at about the same time or before
     6        McDonald's did so?
              A.  Well, not before we did so.  We were the first company
     7        in our industry -- I really think the first company in any
              industry, but for sure the food service industry -- to
     8        make this announcement that we made in August.  Others did
              follow next year, the following year; others in the food
     9        service industry made a similar commitment.
 
    10   Q.   At the time in August 1987 when McDonald's decided that it
              would switch out of CFCs, did it make any public
    11        announcement about that fact?
              A.  Not to my knowledge.
    12
         Q.   Do you recall there was an international treaty Convention
    13        on Protocol signed in Montreal on 16th September 1987, the
              month following McDonald's decision to phase out?
    14        A.  I am aware of that, yes.
 
    15   Q.   Was there considerable publicity following that treaty?
              A.  By McDonald's?
    16
         Q.   No, no.  I mean worldwide or, as far as you were
    17        concerned?
              A.  Yes, I sure read a lot about it, yes.
    18
         Q.   Can you take the pink volume marked large Roman V?  Turn
    19        to divider 22 which is the second one in that volume.
 
    20   MR. MORRIS:  Volume V.
 
    21   MR. RAMPTON:  Volume V, tab 22, page 494, yes?  This is a
              document we looked briefly at yesterday with
    22        Mr. Kouchoukos who was at this time your subordinate at
              Perseco, is that right?
    23        A.  Yes.
 
    24   Q.   Here we see a document, apparently, produced by the
              Natural Resources Defence Council, the Environmental
    25        Defence Fund and Friends of the Earth.  As his Lordship
              said, everyone, at any rate in the country, has heard of 
    26        them.  You have now told us all about the Environmental 
              Defence Fund.  Are you able to tell us something about the 
    27        Natural Resources Defence Council?
              A.  They are a very similar group to the Environmental
    28        Defence Fund.  They headquarters are New York City.  Their
              membership in size is very similar to EDF.  They are
    29        probably either the fourth or fifth leading organisations
              in the United States respectively.
    30
         Q.   Is it, in your experience, unusual to find a joint

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