Day 010 - 11 Jul 94 - Page 16


     
     1        A.  Well ----
 
     2   Q.   Ethylene?
              A.  The manufacturing process of styrofoam produces a
     3        number of wastes, and we identified them in research that
              had been conducted by the Federal Government in 1987, the
     4        so called Minimization of Hazardous Waste Report which
              immediately follows the entry from the encyclopaedia in
     5        the fact pack collection in that exhibit.  It is not a
              complete report, but it is part of the material we
     6        circulated.
 
     7   Q.   What is that called?
              A.  It is the USEPA -- that is the Environmental
     8        Protection Agency Report.
 
     9   Q.   What is it called again?  What is the document?
              A.  It is a one page document.
    10
         Q.   One page document.  It is not in the fact pack?
    11        A.  Yes, it is in the fact pack.
 
    12   MISS STEEL:  Could you hold the page up?
              A.  Yes, I will hold the page up.  This document refers to
    13        and I have referred -----
 
    14   MR. JUSTICE BELL:  What has it written on the top?
              A.  It says USEPA 1986 October, Minimization of Hazardous
    15        Waste.
 
    16   MR. MORRIS:  It is actually the document before that last
              document, so I think it was about the seventeenth page,
    17        eighteenth page.  Can you just explain what this document
              is again and what it says, the significance?
    18        A.  It is a component, a piece of a report.  It is table
              2A of a report issued by the US Environmental Protection
    19        Agency in 1986 under the title Minimization of Hazardous
              Waste, and the title is List of Major Projects Based on
    20        Nationwide Hazardous Waste Generation Rates.  I would call
              your attention to No. 5 on that list, polystyrene/ABS.
    21
         Q.   What is No. 4 on that list?
    22        A.  It is ethylene, No. 6 is Benzyne.  Our research
              indicated Ethylene and Benzyne were chemical precursors in
    23        the manufacture of polystyrene, so with this kind of
              report we were able to identify styrofoam food packaging
    24        as a product that was related to the manufacturing process
              in such a way that large amounts of hazardous waste were
    25        generated in the manufacturing process of this type of
              material. 
    26 
         Q.   Are there any particular problems, for example, with 
    27        Benzyne?
              A.  Well, Benzyne is a known human carcinogen; it has been
    28        linked to leukaemia.
 
    29   Q.   Who has it been linked to leukaemia by?
              A.  Federal Government, a number of studies, a wide
    30        variety of literature has identified it as such.  It is
              what you might say common knowledge within the United

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