Day 009 - 08 Jul 94 - Page 41
1 technical information from the US. So that if you were to
go through a similar exercise anywhere else, all the facts
2 and all the figures would not be the same.
3 Q. Why is that? I thought Perseco in Europe was part of the
same company?
4 A. Yes.
5 Q. So you could, I mean, you have all the technology; you
just have to send a few papers over to this country?
6 A. Remember that Perseco, what they are is they are a
purchasing administration company. They do not, they are
7 material neutral. They have no -- not only do they have
no ownership in McDonald's, they have no ownership of
8 anybody in the supplier community.
9 So they work with the manufacturing community, but they do
not make anything, so they cannot just go out there and
10 say: "Well, we will make foam packaging" because they do
not own any plants.
11
Q. I thought both you and Mr. Kouchoukos have said that if
12 McDonald's tells Perseco to do something, they will do it?
A. Yes, within the powers that they have. However, they
13 are not a manufacturing facility. They do not build
buildings and they do not make packaging.
14
MR. JUSTICE BELL: Could I just understand? You said,
15 reasserted, at the beginning of today that there were four
criteria: Environment, customer impact, operational
16 efficiency, costs and availability?
A. Correct.
17
Q. Are you saying that an assessment of those factors would
18 be made in the States and you would you come up with
answer A?
19 A. Yes.
20 Q. If you make an assessment of those four factors in the UK,
you may come up with answer A, or you may come up with
21 answer B; is that what you are saying?
A. That is what I am saying, and in this case here I just
22 underscore the phrase "availability", so you have to take
a look at the availability of manufacturing, and so on,
23 which is different.
24 MISS STEEL: We will ask Mr. Oakley about that one. Just a
small point: Has McDonald's ever used the term
25 "styrofoam" to describe its polystyrene foam packaging?
A. Not that I am aware of.
26
Q. But it is a well used phrase in the United States, is it
27 not?
A. It is a -----
28
Q. A slang term or whatever?
29 A. It is a well used misused phrase, yes, one in which
Dow Chemical is working very hard. It is their trademark
30 name; they are working very hard to protect their
trademark.
