Day 293 - 04 Nov 96 - Page 21


     
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     2   MR. MORRIS:   Page 2 has a handwritten page 2, bundle page 51.
     3        I don't know what it is about McDonald's figures, but it is
     4        always really hard to work out what is actually going on in
     5        a simple way.
     6
     7        It is quite a helpful series of figures.  Then the
     8        conclusion on bundle page 54 is the total paper packaging
     9        consumption at that time, 1992 was 263 million pounds, in
    10        the middle of page 54.  Now, that is not including -----
    11
    12   MR. JUSTICE BELL:   Just let me find that.  (Pause)
    13
    14   MR. MORRIS:   That does not include any transport packaging.
    15
    16   MR. JUSTICE BELL:   Where is the 263?
    17
    18   MR. MORRIS:   363 is in the middle of page 54, on the right-hand
    19        side, as far as I can see.  Again, I am not 100 percent
    20        sure if the column that says "case consumption" is, in
    21        fact, the transport packaging; but, if it is, it does not
    22        include the food transport packaging, which is more
    23        substantial than the packaging packaging.  It has got
    24        plastic packaging and other packaging.
    25
    26        It may be worth noting that the other packaging is still
    27        not the transport packaging.  That is on page 56.
    28
    29        So it is something like, for the USA alone, 500 million
    30        pounds or a quarter of a million tons, something like that,
    31        as far as we can see.  That seems to be the Persico
    32        material, not everything.
    33
    34        Then, on page 57, it actually goes to look at which items
    35        actually have recycled content; and if you notice that
    36        there are only a few items that do have recycled content,
    37        out of that great long list of all those items that we just
    38        looked at before.  The total claimed, if you look at the
    39        last but one column, post-consumer waste, or post-customer
    40        waste, is 90 million pounds.  So something like 90 million
    41        out of -----
    42
    43   MR. JUSTICE BELL:  It is very roughly 40 percent, is it not?
    44
    45   MR. MORRIS:   It is 40 percent of the recycling content of the
    46        recycled items, but it is less than 20 percent of the total
    47        packaging volume.  This is in 1992.  If you look at all
    48        -----
    49
    50   MR. JUSTICE BELL:  Just pause a minute.  So, about 40 percent of 
    51        the recycled content; and you say about 20 percent of the 
    52        total packaging. 
    53
    54   MR. MORRIS:   Yes.  So, for example, when McDonald's say --
    55        well, I mean, you have to draw your own conclusions,
    56        really.  We are certainly relying on these figures as being
    57        somewhat more extensive than anything else that we have to
    58        rely on.
    59
    60        So, even by 1992, when they say they have increased their

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