Day 007 - 06 Jul 94 - Page 48


     
     1        determined that McDonald's contributed 1.3 billion cubic
              feet of foam food packaging waste to the nation's waste
     2        stream annually". Do you know anything about that?
              A.  Well, I know that no information was requested to make
     3        that calculation.  So, I am not sure where Mr. Lipsett may
              have gotten his information.
     4
         Q.   Do you have a figure for the amount of polystyrene foam
     5        food package contributed by McDonald's to the waste stream
              annually?
     6        A.  I did do a calculation on that and it turned up some
              50 or 60 fold less than what is stated here.
     7
         MR. MORRIS:  50 or 60?
     8
         MR. RAMPTON:  Fold.
     9
         Q.   So we divide Mr. Lipsett's 1.3 billion by 50 or 60 to get
    10        near the right figure?
              A.  Correct.
    11
         Q.   Then next, "Although McDonald's claimed that they were
    12        recycled foam this assertion  ... When the plastic
              industry began ranking plastics by their recyclability.
    13        Polystyrene foam received the lowest classification- an
              eight on a scale of one to eight". Are you conscious, Mr.
    14        Kouchoukos, that the plastics industry began to rank
              plastics by their recyclability in any state?
    15        A.  I am not aware of them ranking plastics by their
              recyclability at all.  The Society of Plastics Industry
    16         /did put a marking on plastic packages.  He says 1
              through 8.  It is actually 1 through 7.  He says
    17        polystyrene is an 8 and it was labelled as a 6.  The sole
              intention of the labelling process was to identify what
    18        type of material the packaging container was made from.
              It was not meant to imply recycleability, nor was it meant
    19        to rank relative recycleability of materials.
 
    20   MR. RAMPTON:  Would that be a convenient moment?  I may have
              one more question of Mr. Kouchoukos at two o'clock.
    21
         MR. JUSTICE BELL:   Are you going to ask any more about Mr.
    22        Lipsett.
 
    23   MR. RAMPTON:  No, I have finished with Mr. Lipsett.
 
    24
         MR. JUSTICE BELL:  Miss Steel, Mr. Morris, you have probably
    25        already thought of it but might I suggest you copy that
              part of the transcript which has Mr. Kouchoukos comments 
    26        on Mr. Lipsett's statement so that Mr. Lipsett can 
              certainly read that through.  If you can fax it to him in 
    27        the States before he comes over, so he has more time to
              think about it, so much the better.   I do not know
    28        whether among the documentation there any of the
              publications or research papers which he presumably had in
    29        mind.  If they are not in the bundles it may be of
              importance that Mr. Lipsett brings copies of them with
    30        him.  Where we have, for instance, EPA National Human
              Adipose Tissue Survey for 1986, he has got a copy of that,

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