Day 010 - 11 Jul 94 - Page 19


     
     1        to cover.  There are a number of studies that have
              documented this.  There are some studies that have
     2        documented this same pattern in Great Britain.
 
     3   Q.   Are there any other examples of volatility of the
              production process for polystyrene?  Do you know of any
     4        problems in a particular factory?  I am referring to a
              particular plant in Texas, for example?
     5        A.  Well, without getting into any detail, the polystyrene
              foam plant in -- it is an Arko plant----
     6
         Q.   Just tell us what happened.
     7        A.  It blew up, and 17 employees were killed in that
              accident.  In that case the government found that there
     8        were no violations -- actually the corporation agreed to
              pay a penalty, but denied any guilt related to problems
     9        associated with their safety procedures and so forth.  It
              is July 5th, explosion in 1990.
    10
         MR. JUSTICE BELL:  What was the plant manufacturing?
    11        A.  Polystyrene manufacturing plant.
 
    12   MR. MORRIS:  There were no violations that the inspectors
              identified?
    13        A.  Well, the members of the families of the workers
              testified that the workers at the plant "Lived with the
    14        fear of losing their jobs if they refused to work" under
              unsafe conditions.  It is also noted that the explosion
    15        created a shortage of foam in the marketplace because it
              was such a large manufacturing facility.
    16
         Q.   Right.  Before we move on, you were going to refer us to
    17        one document, were you not?  I believe it was the EPA
              Dioxin Risk Characterisation.  Is that the one?  You did
    18        allude to a document.
              A.  Sorry?
    19
         Q.   You did mention a document, but I may have it wrong.  The
    20        EPA document you were going to refer us to?
              A.  No, at this point -----
    21
         Q.   We can move on?
    22        A.  I think we can move on.
 
    23   Q.   OK.  After the manufacture of, is it polystyrene and then
              the blowing agents come into play?
    24        A.  Yes.  In order to create a foam package, it is
              necessary to blow gas into the foam, into the polystyrene
    25        itself, so that it will become lighter and will be more --
              it will be lighter and will have certain properties that 
    26        are desirable in the foam food package itself. 
  
    27        To be specific, early in the campaign in 1987 the
              Vermonters Organise for Clean Up targeted McDonald's use
    28        of foam based in part on the fact that the foam food
              package blowing agent, CFC, or chloro-fluorocarbon, caused
    29        damage to the ozone layer.  I note that on August 1st of
              that year the Vermonters Organise for Clean Up acted and
    30        picketed restaurants in Vermont.  Five days later, in
              concert with a number of manufacturers, McDonald's

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