Day 007 - 06 Jul 94 - Page 62


     
     1        A.  Formal report?
 
     2   Q.   The formal study.  When was the first overall,
              comprehensive formal study on the reduce, re-use, recycle?
     3        A.  I do not know that there ever was a comprehensive
              study on reduce, reuse or recycle that we did.
     4
         Q.   There has never been a comprehensive study?
     5        A.  I am not sure what you might be referring to, no.  We
              study each item individually as they come up.
     6
         Q.   So you have never done a comprehensive overview of the
     7        packaging as a whole?
              A.  No.
     8
         MR. JUSTICE BELL:  What you are saying with regard to those is
     9        from the 80s then, those would be in your mind in relation
              to whatever you did; is that what it boils down to?
    10        A.  I am not sure if I understand that point.
 
    11   Q.   What is being put to you is there was no formal study
              looking at those three aspects in relation to packaging?
    12        A.  To overall packaging, no.
 
    13   MR. MORRIS:  What about the environmental defence funds and
              their joint study with McDonald's Corporation on their
    14        packaging, that was a formal comprehensive study, yes?
              A.  That was a study that Perseco and McDonald's was
    15        involved in 1990, that they did look at a lot of
              operational aspects and packaging.
    16
         Q.   So that was a comprehensive reduce, re-use, recycle study?
    17        A.  Yes, that would be.
 
    18   Q.   Was that a big step forward for McDonald's when they did
              that?
    19        A.  It gave us a lot of perspective on where we had
              opportunities.
    20
         Q.   Before that you do not know of any study?
    21        A.  No.
 
    22   Q.   Just give me a moment to collect my thoughts.  You said
              source reduction was the best for restricting the damage
    23        to the environment -- the best of the options?
              A.  In the US we prefer source reduction to reduce
    24        environmental impact, yes.
 
    25   Q.   Why is that?  Is that because you think the overall volume
              is something which is the first priority to reduce? 
    26 
         MR. JUSTICE BELL:  Does it not speak for itself?  If you 
    27        reduce, then that which you reduced it by, you need not
              bother about reusing or recycling because you have cut it
    28        off before birth, is that the reason?
              A.  That is the perspective, yes.
    29
         MR. MORRIS:  If you reduce the overall volume, say, of
    30        McDonald's packaging, that will have an improvement on the
              environment obviously, yes?

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