Day 007 - 06 Jul 94 - Page 32


     
     1   Q.   You mean the total weight of paper used annually?
              A.  Right, yes, and the weight of one wrap versus one foam
     2        container is proportionately that much greater, but it is
              not as significant as one would expect.
     3
         Q.   Here we are talking about paper?
     4        A.  Yes.
 
     5   Q.   The tonnage of paper used in 1992 is 181,000 as compared
              with 158,000 in 1989.  What I am asking is this: Is this
     6        difference accounted for by the change from polystyrene to
              paper?
     7        A.  Yes.  It is accounted for by the foam phased out, yes.
 
     8   Q.   But the effect appears to have been gradual in this sense-
              it only got to 166 in 1991; is that right?
     9        A.  Yes.
 
    10   MR. JUSTICE BELL:   I do not understand that.
 
    11   MR. RAMPTON:  The evidence was that in 1990 McDonald's took the
              decision to abandon, to a large extent, polystyrene foam
    12        in favour of paper.  One result is that by 1992 a good
              deal more paper was being used than had been used in 1989.
    13          There was an intervening stage in 1991 where the
              increase is not so striking.  That is all.
    14
              Was the process of introduction of paper as a wrapping
    15        substance a gradual one?
              A.  It was.
    16
         Q.   If you calculate 51 per cent- and I now want to look at
    17        the 1992, I am going to pursue it from there, roughly
              speaking ---- have you got a calculator, should you need
    18        one?
              A.  I do.
    19
         Q.   Perhaps you would let me do it.  If I am wrong, you can
    20        correct me.  51 per cent of 181,639 is 92,878?
              A.  Yes, it is.
    21
         Q.   Does that mean that the unrecycled, or virgin, content of
    22        McDonald's paper packaging was 88,761 tonnes for that
              year?
    23        A.  It does.
 
    24   Q.   It does?
              A.  Yes.
    25
         Q.   You can put away the yellow file and take out -- no, that 
    26        is a mistake.  You have to go back to the front of the 
              yellow file. Turn to page 59, still in yellow III? 
    27        A.  Yes.
 
    28   Q.   Have you got that page?
              A.  I have.
    29
         Q.   Page 59, this is a huge, fat document.  It runs to over
    30        250 pages and produced by the United States Department of
              Agriculture Forest Service; is that right?

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