Day 063 - 07 Dec 94 - Page 33


     
     1        have some skeletal waste.  That is post-industrial waste.
     2
     3   Q.   So it is ----
     4        A.  So, they are actually not a paper producer or anything;
     5        they are a converter.  They do not have possibilities to
     6        make paper.  So what would normally happen to that waste is
     7        it would end up in an industrial waste stream or in a
     8        municipal waste stream.
     9
    10   Q.   I just want to follow that through.  They do not themselves
    11        recycle those off-cuts or bits of waste; is that right?
    12        A.  They do not.
    13
    14   Q.   So what happens?  Does somebody else have to come and pick
    15        it up or do they take it somewhere?
    16        A.  It varies -- that varies.  In general, it is so that
    17        somebody will have to come and pick it up.
    18
    19   Q.   And it goes elsewhere to be recycled?
    20        A.  Yes.
    21
    22   Q.   By somebody else?
    23        A.  Yes.
    24
    25   Q.   Or by themselves if they happen to have a recycling plant,
    26        I suppose?
    27        A.  If they do, yes.
    28
    29   Q.   Does that sort of a progression also apply to polystyrene,
    30        do you know?
    31        A.  Yes, similar.  As I said, we do not consider recycling
    32        if a supplier again out of a sheet produces lids and the
    33        skeletal waste goes into a shredder at the end of the
    34        machine and is being fed back into the beginning of the
    35        machine as being raw material.  We do not consider that
    36        recycling.
    37
    38   Q.   Thank you.  Now I want to ask you about something else:
    39        Yesterday we were looking at the front page of those, not
    40        the very latest documents, but the ones you produced quite
    41        recently the other day which has a diagram of the top
    42        colour paperboard material.  Can you find that?  Keep
    43        volume IV of the pink ones beside you because I am going to
    44        ask you to have a brief glance at that in a minute.  But
    45        take the diagram of the cross-section, if you can find it?
    46        A.  Yes.
    47
    48   Q.   The one prepared by Mr. Kouchoukos, January 1991.  You told
    49        us when you look at this you have to imagine putting the
    50        food on top of the diagram? 
    51        A.  Yes. 
    52 
    53   Q.   On top of the clay coating, 27 grammes.  Do you remember
    54        you told his Lordship that you thought the reason why the
    55        clay coating at the top was thicker than it is at the
    56        bottom is that the food was on it?
    57        A.  Yes.
    58
    59   Q.   Do you know what are the reasons why a recycled paperboard
    60        container of this kind has a substantially five times

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