Day 010 - 11 Jul 94 - Page 58


     
     1   Q.   Mr. Lipsett, you do not have any scientific or technical
              qualifications, do you?
     2        A.  I have qualifications in the technical area related to
              statistical analysis.  My qualifications specifically are
     3        that I engaged in and trained in history and research, and
              I am experienced with environmental issues and research on
     4        environmental issues.
 
     5   Q.   Have you done a second degree in law?
              A.  Well, the requirements for that, the requirements for
     6        that programme, yes, are that I examine a study.
 
     7   Q.   I expect all those disciplines teach you the need for
              caution and accuracy when you come to make factual
     8        statements, do they not?
              A.  Yes.
     9
         Q.   This statement which you put into your report for this
    10        hearing which is a hearing before a judge in court is not
              fair or accurate, is it?
    11        A.  I would say I am aware of the inaccuracies that are
              raised by the witnesses and I am aware of the ones you are
    12        raising now.
 
    13   MR. JUSTICE BELL:  Did you think that McDonald's was the
              largest single user of polystyrene?
    14        A.  The intent of that statement, if you look at it, is to
              address the issue of McDonald's use of foam food
    15        packaging.  Now, the error that is incorporated is simply
              the statement that McDonald's is the largest single user
    16        of polystyrene, and since I reviewed the material now
              I can see it would simply require a removal of that
    17        particular line, so that it read:  "McDonald's is the
              largest single user of foam, polystyrene foam food
    18        packaging".
 
    19   MR. RAMPTON:  Yes.  There is an enormous use in the United
              States, is there not, Mr. Lipsett, of polystyrene foam
    20        largely in this category made of styrofoam which is used
              in the construction industry, is there not?
    21        A.  There is foam used in construction for insulation
              purposes, that is correct.
    22
         Q.   Probably over 50 per cent of foam used in the United
    23        States is used for insulation in the construction
              industry, is it not?
    24        A.  I cannot speak to that.
 
    25   Q.   You cannot?
              A.  That is correct.  I cannot speak to that. 
    26 
         Q.   Why can you not speak to it?  You are interested in the 
    27        disposal of inert, unbiodegradable substances such as
              polystyrene foam, are you not?
    28        A.  Well, No. 1, the use in the construction is not the
              same thing as the disposal of fastfood packaging.
    29
         Q.   I am lost.  What happens when a house is pulled down?
    30        What happens to all that inert, unbiodegradable
              polystyrene foam?

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