Day 063 - 07 Dec 94 - Page 34


     
     1        greater clay coating on the inside next to the food, what
     2        are the reasons for putting that coating on in the food
     3        side?
     4        A.  It is, in general, to separate the recycled material,
     5        to separate any possible contaminations from the recycled
     6        material coming into contact with the food, providing a
     7        larger barrier for that.
     8
     9   Q.   So far as this country is concerned, the legal implications
    10        for the company if a person should ingest contaminated
    11        material from a food container are a matter for his
    12        Lordship.  Do you happen to know what the legal
    13        responsibilities or liabilities of the company might be in
    14        other countries of Europe if that should happen?
    15        A.  I think it is comparable.
    16
    17   Q.   We will have to perhaps take that up in another way on
    18        another occasion.  If you have the pink IV there?
    19        A.  Yes, I have.
    20
    21   Q.   Could you turn, please, first of all, to page 223 which is
    22        in tab 5?  Do you remember you were asked about this by one
    23        of the Defendants earlier?
    24        A.  Yes.
    25
    26   Q.   I ask you to notice that there is a reference there in the
    27        second complete paragraph to a report or two reports by
    28        Franklin Associates in the paragraph beginning "EDF
    29        prepared"?
    30        A.  Yes.
    31
    32   Q.   Can you turn back to tab 3 of this same file, please?  You
    33        will see at the beginning that this is a report prepared by
    34        Franklin Associates for Perseco?
    35        A.  Yes.
    36
    37   Q.   Which seems to summarise two reports of 1990 and 1991.  Can
    38        you, please, turn to page 125 which is a chart or table
    39        rather, I should say, headed "Display 2", do you have that?
    40        A.  Yes.
    41
    42   Q.   These are, of course, American figures.  Here are set out,
    43        or apparently set out, the competing environmental
    44        advantages and disadvantages of the various kinds of
    45        wrapping.  Do you see them?
    46        A.  Yes.
    47
    48   Q.   Total energy requirement; energy credit from incineration;
    49        is that where the energy is taken from the incineration
    50        plant and used for domestic or industrial purposes?  Is 
    51        that what it means or do you not know? 
    52        A.  Sorry, can you repeat that question?  I missed what you 
    53        are saying.
    54
    55   Q.   The second column, "energy credit from incineration", do
    56        you know what that means?
    57        A.  Oh, yes.
    58
    59   Q.   Which is?
    60        A.  It is if you incinerate that type of packaging, what

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