Day 009 - 08 Jul 94 - Page 67


     
     1        from your own figures?
              A.  If you are going to refer to this, this time I would
     2        like to have the document in front of everybody.  I think
              it is important that we look at.
     3
         MR. RAMPTON:  May I ask which document the witness would like?
     4        A.  Yes, I can tell you which one that we should look at.
              It should be volume IV, page 215.
     5
         MR. MORRIS:  Was it not out of your statement?
     6        A.  It should be volume IV, page 215.
 
     7   MR. JUSTICE BELL:  Try not to cover the ground Miss Steel
              covered.
     8
         MR. MORRIS:  No, I am just going to try and clarify -----
     9        A.  I am glad you did not want to do that because the
              question this morning was incorrect.
    10
         Q.   Not to get bogged down, but the average waste per store,
    11        solid waste per store, is what?
              A.  OK.  Let me, I think, have one minute so I can clarify
    12        this.  Does everybody have that page open, 215.   The
              question I received this morning was McDonald's produces
    13        149 pounds per day per restaurant of on premise waste.
              That was not a correct question.
    14
         MR. MORRIS:  OK.
    15        A.  Because what this chart represents is all of our
              consumer packaging basically.  This is our consumer
    16        packaging that is quantified, so that includes consumer
              packaging that is delivered to our restaurant.  In
    17        approximation half of it is eaten on premise, half of it
              goes out.  So that 149 pounds per day per restaurant
    18        represents all the consumer type packaging that is
              delivered to the restaurant and divided by an estimate of
    19        the amount of customers that we would serve in both areas,
              drive-through and sit down, which approximate to be 2,000
    20        customers a day.
 
    21   Q.   So, does this represent just what the customers themselves
              get in their hands?
    22        A.  Yes.
 
    23   Q.   They get on average per day 149 pounds in their hands and
              some of them walk out with it and some of them put it in
    24        bins in the store?
              A.  That is a good way of putting it.
    25
         Q.   So this does not include ----- 
    26        A.  The next page -- so let me explain this page.  I 
              can explain this very simply.  This is an on premise -- 
    27        what we call a waste characterisation study -- this was
              based on samplings that we took at our restaurants to
    28        measure the actual waste that is in our garbage bins in
              the back corner of our lot.
    29
              So, as you can see here, this would show 238 pounds per
    30        day per restaurant at a given site -- let me just complete
              this, if I could, because I think this is an important

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