Day 010 - 11 Jul 94 - Page 31


     
     1
         Q.   Whilst on that subject, what did you conclude with regard
     2        to that use?
              A.  In a very general sense, we concluded it was a
     3        wasteful product.  It was a wasteful package material.  It
              was nothing particular.  It was not a particularly useful
     4        package, except it was a vehicle for McDonald's to put its
              name on, its product, and to -----
     5
         Q.   Would you say that was an extravagant use?
     6        A.  In so far as they relied upon the package to use as an
              advertising device on television, they were, it was a
     7        series of advertisements that ran in the United States
              which referred to the package under the guise of the
     8        "keeping the hot side hot and the cold side cold", and
              subsequently using the package for the brief period of
     9        time that the customer would come in contact with it.
 
    10   Q.   So, is it fair to say that you considered it was more of
              an advertising tool than anything else, or promotion?
    11        A.  That is correct.
 
    12   Q.   The issue of migration which I think at the previous
              hearing we called "leeching", what was your analysis of
    13        this problem?  If you can refer us to any documents, then
              please do so.
    14        A.  I would call your attention to a document in this
              collection which is titled Styrene Migration into Human
    15        Adipose Tissue.
 
    16   MR. JUSTICE BELL:  No. 4.
              A.  Also as a supporting document, the document titled
    17        Broad Scan Analysis of Fiscal Year 1982, National Human
              Adipose Tissue Survey Specimens, volume 1, Executive
    18        Summary.
 
    19   MR. MORRIS:  I have one document.
 
    20   MR. JUSTICE BELL:  I think you may find they are both in the
              same bundle.  What is the second one called?
    21        A.  On the cover it has a picture of the United States and
              it is called Broad -- it has EPA in the left-hand corner,
    22        Broad Scan Analysis of Fiscal Year, FY 1982.
 
    23   MR. MORRIS:  So it is No. 4 and No. 8 in our bundles?
              A.  That would be, I guess, correct.
    24
         Q.   Have we all got the same documents?
    25
         MR. JUSTICE BELL:  Yes. 
    26 
         MR. MORRIS:  Which one are you referring to first? 
    27        A.  I would refer to the Styrene Migration into Human
              Adipose Tissue article first.
    28
         Q.   Who is this by?
    29        A.  By George Baggett.
 
    30   Q.   Do you know who George Baggett is?
              A.  I have met him; I cannot say I know him.

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