Day 008 - 07 Jul 94 - Page 44


     
     1        A.  The same bundle?
 
     2   Q.   Yes, the same bundle.  Keep your finger in where we are at
              page 140.  What do we see there?  What is this document?
     3        A.  This document was prepared by Franklin Associates for
              the Perseco company.  It is an analysis of different
     4        sandwich packaging options from an environmental profile
              perspective.
     5
         Q.   As between paper and polystyrene foam, what was the
     6        conclusion, the points on environmental benefit, the
              conclusion to which Franklin Associates came in this
     7        analysis?
              A.  The conclusion they came to was that foam had a less
     8        environmental -- "impact" is not the right word.  They had
               -- the reason I am being careful with my words is what
     9        the researchers in this field do, is they do not assess
              risk assessment.  What they assess is just numbers.  So,
    10        they did not come to any conclusions as to what is better
              than the other.  The conclusions had to be drawn by the
    11        reader.  So that is why I was hesitating in answering the
              question.  They did not come to any conclusions besides
    12        giving us numbers to look at.
 
    13   Q.   That is perfectly right.  I should have phrased my
              question differently.  If you turn to page 125, this is
    14        part of the Franklin Associates' report, we have of the
              sideways table called Display 2?
    15        A.  Yes.
 
    16   Q.   This is part of their analysis?
              A.  Yes.
    17
         Q.   In the left-hand column you see the material in question,
    18        and in the far right-hand column you see its
              characteristics by weight and by volume as solid waste?
    19        A.  Correct.
 
    20   Q.   We see that standard paper wrap, this is for 10,000
              packaging products, I think, is it not?
    21        A.  Yes.
 
    22   Q.   Standard paper wrap, the volume is two cubic feet?
              A.  Correct.
    23
         Q.   We see that for polystyrene foam the container the volume
    24        is 16.5 cubic feet?
              A.  Correct.
    25
         Q.   So on this basis, plainly, if we are talking about simply 
    26        volume of solid waste, then paper has it over polystyrene 
              foam? 
    27        A.  Correct.
 
    28   Q.   Can you go back to page 140 which is the EDF McDonald's
              document.  It goes on:  "Source reduction can similarly
    29        reduce environmental impacts in the production paper
              packaging items.  For example, McDonald's is systematic in
    30        reviewing its use of chlorine bleach paper products with
              the intention of reducing the use of this type of paper

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