Day 009 - 08 Jul 94 - Page 69


     
     1
         Q.   No, packaging on premises waste is what I was referring
     2        to.
 
     3   MR. MORRIS:  It says in the statement: "The average McDonald's
              restaurant produces about 140 pounds of packaging on
     4        premises waste per day".
 
     5   MISS STEEL:  That is your statement?
              A.  That is incorrect.
     6
         MR. MORRIS:  Just One further question, not to get even more
     7        confused, there are restaurants that are entirely
              drive-ins?
     8        A.  Are you saying do we have restaurants that are
              entirely drive-ins?
     9
         Q.   You do not have restaurants that are entirely drive-ins?
    10        A.  I think there are some that might be like a couple, I
              do not know the number.  If we do have any, it would be a
    11        small amount in number, a small number.
 
    12   Q.   Let us forget that.  Just a couple of extra questions.
 
    13   MR. JUSTICE BELL:  Do I understand, looking at page 216, that
              that is based on only two restaurants over one week?
    14        A.  Yes, we try to pick restaurants that we thought were
              the typical McDonald's restaurants.  Every year we have
    15        done similar waste characterisation studies with other
              restaurants.
    16
         Q.   I am not a statistician, but two restaurants over one week
    17        would appear to be in no way statistically significant,
              but you picked what you thought were two typical ones, and
    18        what you have done since has tended to validate that, has
              it?
    19        A.  Yes.  We deem it is very important to take actual
              measurements of our waste in order to know what is
    20        happening.
 
    21   Q.   All I am asking you, if you just took two restaurants over
              a one week period and then said whether that is an
    22        accurate reflection of McDonald's US wide, I would guess,
              without knowing, that most statisticians would say that
    23        has to be ridiculous?
              A.  I agree with that.
    24
         Q.   But you picked two which were typical; what you have done
    25        in subsequent years has tended to show this to be
              accurate, has it? 
    26        A.  Yes, also that is why it is important that we always, 
              you see all those packaging -- so we balance what we find 
    27        in reality, we balance that with what we know we are
              purchasing, so we try and reconcile them.  In general they
    28        do reconcile.
 
    29   Q.   So you would stand by this?
              A.  Yes.
    30
         MR. MORRIS:  I am just checking through if there are any last

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