Day 009 - 08 Jul 94 - Page 12


     
     1
         MR. JUSTICE BELL:  Can I ask you why they are called "pulp
     2        trays"?
              A.  The reason they are called pulp trays, I have been to
     3        all the suppliers who have made pulp trays for McDonald's
              in the United States.  They use exclusively newspapers,
     4        for example; newspapers come into the plant.  They are put
              into a big blender, I will call it, and it is pulped,
     5        blended.  What you end up with is a pulp slurry.  That is
              simply, I will call it, it is baked -- it is baked into
     6        the form of a tray that you see.  That is why we call it a
              "pulp tray".
     7
         MR. MORRIS:  Generally are they considered to be packaging i.e.
     8        they would be disposed of in bins, would they, or would
              they be returned to the counter generally?
     9        A.  They would be disposed of.  Let me finish our history
              of recycle paper usage.  Another item that we historically
    10        have used recycled content in, including post-consumer
              paper, is napkins.  In terms of our exact usage of
    11        post-consumer napkins I cannot given a firm date.  Our
              largest supplier in the United States has been Ford
    12        Howard.  When I started at Perseco in 1988, I can tell you
              they had 40 per cent of the business of McDonald's
    13        napkins.  I can tell you that they used pretty much all
              recycled content in the napkins they supplied to
    14        McDonald's.
 
    15   Q.   Post-consumer?
              A.  No, let me finish.  They supplied all their napkins
    16        with recycled content.  On average, it probably averaged
              30 per cent post-consumer.  The balance would have been
    17        preconsumer.  Ford Howard's use -- McDonald's has always
              used napkins from the very beginning.  McDonald's use of
    18        Ford Howard probably goes back to again the 1960's, but I
              would have to check our history on that.  So, again a long
    19        history of using recycled content in napkins, but the
              other suppliers use virgin material to a large degree.
    20
         Q.   For napkins?
    21        A.  Yes.
 
    22   Q.   I am just trying see that of the 40 per cent supplied by
              Ford Howard for the napkins, of that 40 per cent, 70 per
    23        cent was preconsumer and 30 per cent was post-consumer
              recycled content?
    24        A.  Yes, that is absolutely correct.  The other suppliers
              of napkins compose 60 per cent of the business.  I cannot
    25        tell you here what portion they use in terms of recycled
              content.  I would have to research that further.  It would 
    26        not be a significant amount.  The other item we have 
              historically used in terms of recycled content are the 
    27        Happy Meal cartons.
 
    28        I cannot tell you when we started Happy Meal promotions
              etc. within the McDonald's system.  But I can tell you
    29        that whenever we started that we would have used recycled
              content in them.  The largest supplier we used is called
    30        Jefferson Smurfitt, and they have always used a
              combination of preconsumer and post-consumer in the paper

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