Day 061 - 05 Dec 94 - Page 22

     
     1        I am not familiar with which countries he would supply with
     2        recycled content.  Mr. Van Erp would have specific details
     3        of which countries require recycled material from the
     4        French supplier.
     5
     6   Q.   You have said in your statement that they are not produced
     7        from recycled paper?
     8        A.  Generally not, because he does not have it, unless he
     9        is requested to, then they would.
    10
    11   Q.   The one in Scotland, you say, generates his own recycled
    12        paper?
    13        A.  He is one of the biggest collectors of post-consumer
    14        waste in the country.  I personally stood there and watched
    15        truck after truck after truck coming from all over the
    16        country delivering post-consumer waste to that plant.
    17
    18   Q.   That is Smith Anderson?
    19        A.  That is Smith Anderson.
    20
    Q.   Would it possible to have the five-minute break now?
    22
    23   MR. JUSTICE BELL:  Yes.
    24
    25                            (Short Adjournment)
    26
    27   MR. MORRIS:  One brief question on point 26:  You said that
    28        since 1990 you have made considerable reductions in the
    29        amount of plastic packaging due to bulk deliveries and
    30        thinner polystyrene; is that correct?
    31        A.  Yes.
    32
    33   Q.   If we move on, on page 12 you said regarding Europe before
    34        Perseco was established which was around 1991:  "All the
    35        environmental initiatives prior to that time (over 12 years
    36        ago)" -- I cannot understand why it was over 12 years ago
    37         -- "were negotiated direct with suppliers".  Can you just
    38        explain what you mean there?
    39        A.  I think the "over 12 years ago" refers probably to the
    40        first environmental initiative which was at that time 1981
         and Alex Popper.  The McDonald's Purchasing Department
    42         -----
    43
    44   Q.   Sorry, was that the two and four hole trays?
    45        A.  Right.
    46
    47   Q.   Which you said were in any case, if I remember, a very
    48        tiny, virtually insignificant, volume or numbers ---
    49        A.  No.
    50 
    51   Q.   -- two and four hour holes trays were? 
    52        A.  The tiny, virtually insignificant number or volume 
    53        related to the amount of recycling done on two and four
    54        hole trays.  We use a lot of two and four hole trays in the
    55        restaurants.
    56
    57   Q.   All right then.  Before you said that the two and four hole
    58        trays' recycled content was the supplier's idea?
    59        A.  The original thought came from the supplier, yes.
    60