Day 005 - 04 Jul 94 - Page 43


     
     1        A.  That is not environment/index.html">litter.
 
     2   Q.   I am not saying that is dropped on the streets of the
              country but, overall, would you say your figures of
     3        generation of packaging could be in tens of thousands of
              tonnes?
     4        A.  Well, are we talking about environment/index.html">litter or are we talking
              about waste?
     5
         Q.   Taking about general post-consumer packaging volumes, much
     6        of which, no doubt, goes into receptacles in the store?
              A.  Yes.
     7
         Q.   It is fair to say there is ten's of thousands of tonnes?
     8        A.  I have never weighed it.  I am sorry, I do not know.
 
     9   MR. JUSTICE BELL:  Are you going to put to the witness what it
              is McDonald's do not do that they should do, or what it is
    10        they do do they should not do?
 
    11   MR. MORRIS:  Yes, I am coming -- I am just trying to find the
              document that identifies some amounts of waste I could
    12        point to, but I have not got it in front of me.
 
    13   MR. JUSTICE BELL:  You can find that later.  Obviously, there
              is a lot.
    14
         MR. MORRIS:  Let us say, for example, at a most conservative
    15        estimate, that McDonald's in the UK only uses 10,000
              tonnes of packaging, its consumers only use -----
    16
         MR. JUSTICE BELL:  Is this in a year?
    17
         MR. MORRIS:  Here we are, we have this -- it is pink bundle --
    18        I do not think you have to look at it yourself, well, can
              you if you want -- bundle 4.  This is just an example of
    19        the amount.
              A.  Pink bundle 4.
    20
         Q.   Tab 11, I believe this is pages 349 onwards.  It
    21        identifies the amount of tonnes.  I believe this is from
              America.  Someone will correct me if I am wrong, but we
    22        are just talking about the actual amounts.
 
    23   MR. RAMPTON:  My Lord, these are documents produced by Paceeco
              who are worldwide suppliers, but this does relate to
    24        America.
 
    25   MR. MORRIS:  This is for America.  The volumes in America,
              annual tonnes of packaging on page 349 in 1990. 
    26 
         MR. JUSTICE BELL:  The total is on the following page, is it 
    27        not, of nearly 310,000 tonnes?
 
    28   MR. MORRIS:  Yes.  310,000 tonnes in America.  Let us just talk
              about America.  Would you say that the volumes in this
    29        country would be comparable overall, in other words, that
              500 restaurants here and 10,000 in the States, gives
    30        one-twentieth of that approximately a year, something like
              that.  Let us just talk about America then.  300,000

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