Day 009 - 08 Jul 94 - Page 68


     
     1        distinction -- that this includes a portion of the
              previous chart that we just saw.
     2
         Q.   Half?
     3        A.  Approximately 50 per cent of the previous chart.
 
     4   MR. JUSTICE BELL:  That includes what is not taken away by the
              customer?
     5        A.  Exactly.  So if you were to ask me how much total
              waste per day McDonald's produce, the answer I would give
     6        to you is 238 pounds per day per restaurant that we see on
              this chart, that is on our lot, plus half of the other
     7        chart, as a general rule.
 
     8        But just let me qualify that by saying it is not strictly
              McDonald's initiated waste.  So, for instance, on this
     9        chart, non-McDonald's waste is four per cent.  That is
              waste that customers bring into the restaurants
    10        themselves.
 
    11   MR. JUSTICE BELL:  How much?  Four per cent is -- I see, yes.
 
    12   MR. MORRIS:  Obviously it is only an average anyway.
 
    13   MR. JUSTICE BELL:  That is the newspaper they brought in and
              left behind -----
    14        A.  They empty their car before they come to McDonald's,
              they empty their car out.
    15
         MR. JUSTICE BELL:  They do that, that sort of thing?
    16        A.  Yes, very often.
 
    17   MR. MORRIS:  So it is something like 300 pounds a day would be
              a reasonable figure?
    18        A.  I think it is a very reasonable figure to work with.
 
    19   MR. JUSTICE BELL:  What was the figure again?
              A.  300 pounds per day per restaurant, knowing that is a
    20        combination of packaging, it is over the counter, it is
              corrugated boxes which, by the way, we recycle.  So, do
    21        not presume when we use the term "waste", do not presume
              that it is all waste going into a landfill.  It is also
    22        food waste too.
 
    23   MR. JUSTICE BELL:  It includes the corrugated boxes and
              everything of that kind?
    24        A.  Correct, but it is not all disposed of in a landfill.
 
    25   MISS STEEL:  So the figures that I quoted to you this morning
              from your statement were quite a big under-estimate, in 
    26        reality? 
              A.  Well, it depends which way you look at it.  You over 
    27        estimate the packaging, you under estimate the overall
              impact.
    28
         Q.   I was relying on 140 pounds which is what was in your
    29        statement and you have just said it would total somewhere
              near 300?
    30        A.  I think you your mind was packaging.  Now, the answer
              I am going you now -----

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