Day 007 - 06 Jul 94 - Page 43


     
     1
         Q.   So for as are you aware, does Mr. Lipsett have any
     2        technical or scientific qualifications?
              A.  It would not appear so.
     3
         Q.   But you do not know whether it is so, or not.
     4
         MR. JUSTICE BELL:   Are you just relying on his C V?
     5        A.  Yes.
 
     6   MR. RAMPTON:  I will not ask you any more about that.  I want
              you to look with me at some parts of this statement where
     7        I believe you may be able to have factual evidence to give
              about what is said here.  Paragraph 2.  Here he gives his
     8        own dates from October 1987 to November 1990 CCHW which is
              short for Citizens Clearing House for Hazardous Waste co-
     9        ordinated a nationwide grassroots campaign against
              McDonald's and aimed to get McDonald's to stop using
    10        styrofoam food packaging".  Is there a substance called
              styrofoam?
    11        A.  There is a substance called styrofoam.  It is  Dow's
              trade name for home insulation board which is put in your
    12        home structure.
 
    13   Q.   Does McDonald's use any styrofoam in its packaging?
              A.  Not to my knowledge, no.
    14
         Q.   What is the substance called that McDonald's uses for its
    15        packaging?
              A.  Polystyrene foam packaging.
    16
         Q.   "(i.e. In brackets the McToxics Campaign).  During the
    17        campaign I researched the McDonald's company and its use
              of Styrofoam as well as the side effects of the styrofoam
    18        production and use and disposal of styrofoam and the
              disposal and dispersal of the chemical precursors and
    19        waste byproducts used in the manufacture of styrofoam".
              You were at Perseco during that period 1987 to 1990?
    20        A.  I was.
 
    21   Q.   And Perseco were at that date McDonald's sole suppliers,
              is that right?
    22        A.  Yes.
 
    23   Q.   Were you ever approached by this body CCHW?
              A.  No, I was not.
    24
         Q.   For information about McDonald's use of polystyrene foam?
    25        A.  No information was requested.
  
    26   Q.   While we are on it, what is the meaning of the expression 
               'chemical precursor'? 
    27        A.  A precursor would be a building block to make a
              further chemical or a material.
    28
         Q.   Is it a necessary stage in the production of a particular
    29        substance?
              A.  It is.
    30
         Q.   If it is called a precursor is it then a separate

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