Day 008 - 07 Jul 94 - Page 44
1 A. The same bundle?
2 Q. Yes, the same bundle. Keep your finger in where we are at
page 140. What do we see there? What is this document?
3 A. This document was prepared by Franklin Associates for
the Perseco company. It is an analysis of different
4 sandwich packaging options from an environmental profile
perspective.
5
Q. As between paper and polystyrene foam, what was the
6 conclusion, the points on environmental benefit, the
conclusion to which Franklin Associates came in this
7 analysis?
A. The conclusion they came to was that foam had a less
8 environmental -- "impact" is not the right word. They had
-- the reason I am being careful with my words is what
9 the researchers in this field do, is they do not assess
risk assessment. What they assess is just numbers. So,
10 they did not come to any conclusions as to what is better
than the other. The conclusions had to be drawn by the
11 reader. So that is why I was hesitating in answering the
question. They did not come to any conclusions besides
12 giving us numbers to look at.
13 Q. That is perfectly right. I should have phrased my
question differently. If you turn to page 125, this is
14 part of the Franklin Associates' report, we have of the
sideways table called Display 2?
15 A. Yes.
16 Q. This is part of their analysis?
A. Yes.
17
Q. In the left-hand column you see the material in question,
18 and in the far right-hand column you see its
characteristics by weight and by volume as solid waste?
19 A. Correct.
20 Q. We see that standard paper wrap, this is for 10,000
packaging products, I think, is it not?
21 A. Yes.
22 Q. Standard paper wrap, the volume is two cubic feet?
A. Correct.
23
Q. We see that for polystyrene foam the container the volume
24 is 16.5 cubic feet?
A. Correct.
25
Q. So on this basis, plainly, if we are talking about simply
26 volume of solid waste, then paper has it over polystyrene
foam?
27 A. Correct.
28 Q. Can you go back to page 140 which is the EDF McDonald's
document. It goes on: "Source reduction can similarly
29 reduce environmental impacts in the production paper
packaging items. For example, McDonald's is systematic in
30 reviewing its use of chlorine bleach paper products with
the intention of reducing the use of this type of paper
