Day 063 - 07 Dec 94 - Page 12

     
     1        is actually from America?
     2        A.  Yes, it is.
     3
     4   Q.   As far as I can see.  So, although we did bring this up
     5        before, this actual document we have not seen, it seems to
     6        indicate that McDonald's accepts there is a reason for
     7        distinguishing between pre-consumer and post-consumer
     8        waste?
     9        A.  In the US there is, yes.
    10
    11   Q.   It says in the first paragraph:  "This is being done due to
    12        legislation from such states as Rhode Island and due to the
    13        increasing expectations of environmental leaders and
    14        experts to help educate customers regarding this issue"?
    15        A.  Yes.
    16
    17   Q.   So it is considered to be relevant to the environmental
    18        benefits of recycled paper in respect to whether it is
    19        post-industrial or preconsumer?
    20        A.  In the US it is, yes.
    21
    22   Q.   If McDonald's recognises it is important in the US?
    23        A.  Because of legislation, yes, and you are required to
    24        educate the people on that part.
    25
    26   Q.   Why do people think it is important to distinguish between
    27        post-consumer and pre-consumer content?  Why do
    28        environmentalists, environmental leaders, as it says here,
    29        think it is important?
    30        A.  You would have to ask those environmental leaders.
    31
    32   MR. RAMPTON:  My Lord, surely, the right question is whether
    33        Mr. Van Erp knows of any reason to distinguish; not what
    34        other people think; it does not help your Lordship in the
    35        very slightest, not even the Rhode Island State legislature
    36        helps your Lordship.
    37
    38   MR. JUSTICE BELL:  Whether that latter comment of Mr. Rampton's
    39        is right or not, you have Mr. Van Erp in the witness box at
    40        the moment so you can -----
    41
    42   MR. MORRIS:  Do you think it is important, the difference
    43        between post-consumer and post-industrial recycled content?
    44        A.  You are asking for a personal opinion at the moment?
    45
    46   Q.   Yes.
    47        A.  My personal opinion is that I think it is at this point
    48        in time, it is important whether by the use of recycling
    49        you can actually divert paper from going into the local
    50        waste stream.  Whether that is post-industrial -- if that 
    51        industry could not do anything with that material and 
    52        would, therefore, otherwise have dumped it into the waste 
    53        stream, or whether it is mixed post-consumer waste which is
    54        generally more difficult to recycle; if in both areas you
    55        can divert waste from going into the local waste stream,
    56        that is the important thing of recycling, in my opinion.
    57
    58        Therefore, we do exclude in a recycling statement or a
    59        recycled statement items that would very normally already
    60        be recycled, such as the internal recycling which takes