Day 062 - 06 Dec 94 - Page 54


     
     1        going straight. Apart from that most was handled by
     2        ourselves.
     3
     4   Q.   But in terms of what the figures for, say, 1990 on that
     5        chart above there -- actually, that is per store, but say
     6        on the chart of use in Europe on the previous page, if the
     7        comparison was being made -- well, if you had included
     8        figures for the items that are now handled by Perseco but
     9        were at that time not handled through Perseco, what kind of
    10        increase would you be looking at in terms of usage?
    11        A.  I have got no idea.  You would be looking at something
    12        like a few per cent.  As I said, it is mainly smaller items
    13        that were not handled by us by that time.  That is a guess.
    14
    15   MR. JUSTICE BELL:  The material used 1991, is it?
    16        A.  She asked me about 1990.
    17
    18   Q.   I know, but are there some figures we can look at so we can
    19        see what we have to add 2 per cent to?
    20        A.  You can roughly estimate that we are talking about,
    21        what is it, 23,000 tonnes in 1990 in total.
    22
    23   MR. MORRIS:  That is what went through Perseco on the DCs?
    24        A.  That is what went through Perseco.  Now that one 1990
    25        was not prepared by myself.
    26
    27   MS. STEEL:   Where did you get the figures from?
    28        A.  They are from my predecessor David Kouchoukos.  I tried
    29        to make as good as possible a comparison with that, but
    30        there were some discrepancies I tried to describe there.
    31
    32   MR. JUSTICE BELL:  I appreciate Ms. Steel is asking you about
    33        1990, but if you look at the material use 1991 which you
    34        actually prepared ----
    35        A.  Yes.
    36
    37   Q.  --- what sort of percentage would you add to that, just a
    38        ball park figure so we have some idea?
    39        A.  To the best of my knowledge, it would not be more than
    40        between 5 and 10 per cent.
    41
    42   MS. STEEL:  That was mainly cups and things like that, was it,
    43        mentioned about Polar cup?  Would it be polystyrene?
    44
    45   MR. JUSTICE BELL:  I thought it was the tray mats, promotional
    46        items, Happy Meal boxes, and things like that?
    47        A.  No, it would not be those.  Those have never been
    48        included in any of the studies.  They were not meant to be
    49        because we were not responsible for those.
    50 
    51   MR. JUSTICE BELL:  I appreciate that.  I will rephrase my 
    52        question.  What I wanted to know is if one wanted to look 
    53        at material use 1991, add in anything else which uses any
    54        of the materials which are set out in there but have not
    55        come through Perseco, so are not in your material use 1991,
    56        what sort of percentage should we add?  How short are your
    57        figures of total use?
    58        A.  If you want to include promotional items?
    59
    60   Q.   Well, anything used by McDonald's.

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