Day 010 - 11 Jul 94 - Page 15


     
     1        in the top left hand corner and a chemical equation in the
              bottom right-hand corner.  It is an extract from -- can
     2        you give the details?
              A.  It is an extract from the Encyclopaedia of Food
     3        Packaging.  It is a document that is more likely to be
              found in certain departments of organisations that
     4        manufacture and produce foam packaging or in
              universities.  Without getting into detail, I would say
     5        this particular document refers to the variations in the
              manufacture of foam.
     6
              It refers to different types of foam packaging that are
     7        also elaborated in other materials that are in this what
              we would call "fact pack".  It describes with some clarity
     8        in a brief sense the nature of manufacturing of foam.
 
     9        The point is, with regard to this document, that this kind
              of material was widely circulated to local community
    10        activists who were, at their leisure, able to review this
              kind of material and develop their own arguments regarding
    11        this component of the foam food packaging process and
              life-span.
    12
         Q.   Are there any particular parts you would like to refer the
    13        court to?
              A.  I think that, in general, the point that I am trying
    14        to make here is this research was available to Grassroots
              activists.
    15
         MR. JUSTICE BELL:  But what part of the sheet is it that you
    16        pray in aid to what you have said?
              A.  I am sorry, what part of the sheet is it that I am
    17        referring to in aid to what I am saying?
 
    18   Q.   Yes.
              A.  I guess I need to clarify my point here.  The document
    19        itself stands as an example of the kind of material that
              was circulated to Grassroots activists.
    20
         MR. MORRIS:  So it is not a specific sentence; it is just an
    21        example of the work you are doing?
              A.  This is an example of the kind of material that was
    22        engaged, used by Grassroots activists in their campaign to
              get McDonald's to stop using foam.  It is an example of
    23        the kind of -- it is an example of the kind of information
              that people were prepared to address when they took on
    24        this issue.
 
    25        Again this is at the point of manufacture that McDonald's
              foam food package is produced.  It describes certain 
    26        dimensions to that process.  But, aside from the 
              manufacturing process and the way in which foam food 
    27        packaging is produced, we are primarily concerned with the
              emissions and so forth related to foam food packaging
    28        production.
 
    29   Q.   Looking at the production process in a little more detail,
              you say there was specific, shall we say, chemicals.  I do
    30        not know myself, but there is styrene -- is that correct
               -- used in the process?

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