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1. I am Environmental Affairs Manager at Perseco, a position which I have held since 1991. Perseco is the exclusive designer and purchaser of packaging for McDonald's Restaurants worldwide. Prior to becoming Environmental Affairs Manager I was on 8 one year assignment at Perseco Europe Establishing the Environmental Affairs Department for Perseco's then newly opened European Office. I joined Perseco in 1987 in the Packaging Development Department. I have a degree in packaging engineering from Michigan State University.
2. My responsibilities as Environmental Affairs Manager include packaging design, taking into account reductions and recycled content as well as asking the packaging more recyclable and/or more compostable. In addition I monitor packaging legislation and labelling restrictions as well as supplier environmental accountability.
3. In August 1989 I prepared a report for McDonald's on the subject of HCFC-22 Support, a copy of which is attached hereto at "DJK 1". In preparing this report I calculated that in 1988 approximately 600,000 lbs of HCFC-22 was used in manufacturing McDonald's polystyrene foam packaging. This calculation was based on the materials purchased by Perseco in 1988 for McDonald's a and to the best of my knowledge and belief wee correct.
4. Since 1988 the number of countries in the McDonald's system which use polystyrene foam made with HCFC-22 has decreased dramatically as has the amount of HCFC-22 used. By 1992 the only countries In the McDonald's system which used polystyrene foam packaging made from HCFC-22 were Hungary, Turkey, Hong Kong, Singapore, Malaysia, Korea and Thailand.
5. The sole supplier of polystyrene foam for McDonald 's Turkey is Budapest: for Hungary it is Ambalaj Ve Plastik Sanayi Ticaret A.S. and for Hong Kong, Singapore and Malaysia, Korea and Thailand it is Pacific Cup (Hong Kong) ) Ltd. I attach at "DJK 2" letters from these three suppliers which set out the amount of foam they supplied to McDonald's in 1992. As can be seen from these letters in 1992 the amount was approximately 454,000 1bs. In order to manufacture the foam approximately 5% by weight of HCFC-22 is used in the process. I attach at "DJK 3" a letter from DuPont Chemicals of USA who are the major manufacturers of HCFC-22 in the world which confirms that 5% is approximately correct. Consequently I calculate that in 1992 approximately 22,700 1bs of HCFC-22 only was used in manufacturing McDonald's packaging, which Pa a significant reduction in the amount used since 1988.
6, In the Particulars of Justification and Fair Comment the Defendants state that in 1972 Bruce Hannon, an engineer at the university of Illinois determined that 315 sq miles of forest would have to be cut down to keep McDonald's supplied with paper packaging for one year. The Defendants go on to say that since then the chain has doubled clearly implying that the number of square miles of forest to be cut down would have also doubled.
7. In 1992 McDonald's Restaurants in the united States consumed 181,639 tone of paper and paper board packaging. Of this amount 511 or 92,878 tons, was made from recycled paper fibre and consequently did not directly require the harvest of any timber. I attach at "DJK 4" documents which ~ prepared for McDonald's confirming those figures to be correct.
8. I attach at "DJK 5" An Analysis of The Timber Situation in The United States : 1989 - 2040, a technical document supporting the 1989 USDA Forest Service RPA Assessment, written by the United States Department of Agriculture, Forest Service, Rocky Mountain Forest and Range Experiment Station published in December 1990. On page 262, Table Be, the USDA reported that it takes 117.40 cubic feet I of trees on average to make 1 ton of paper or paper board. On page 4g, Table 38 the USDA reports that for combined hard woods a ~ soft woods, there 1e 831,314 million cubic feet of trees on timberland in the US as of 1987. On page 44,
Table 36 the USDA reported that there are 483.3 million acres of timberland in the US as of 1987. These facts dictate that there are 1,720.08 (831,314,000,000 divided by 483,300,000) cubic feet of trees on average per acre of timberland.
9. If there ore 1,720 cubic feet of trees per acre and it takes about 117 cubic feet of trees to make a ton of paper or paper board, then 14.7 (1,720 divided by 117) tons of paper or paper board can be made from 1 acre of timberland per year.
10. In 1992 the amount of paper and paper board consumption of McDonald's would require 6,038 (88,761 divided by 14.7) acres of timberland. As there are 640 acres in a square mile McDonald's required the harvest of 9.4 square miles of timberland for all their paper and paper board packaging. Whilst these figures are for the United States only, approximately 70` of all McDonald's restaurants are In the US and even if the amount of paper board consumption were doubled to take into account the rest of the world (which 1e unlikely to be the case), it can be aeon that the allegations which the Defendants make are totally unfounded.
1. I make this additional statement in response to the defendants' allegations concerning the environmental effects of McDonald's paper packaging.
2 In August 1993 1 prepared a summary of the location of the various paper mills which supplied paper for use in products supplied to McDonald's and the pulp bleaching process used by them. I attach a copy of the summary at "DJK 5" from which it can be seen that all the paper mills which supply paper for use in McDonald's packaging in the U.S. are located either in the U.S. or in Canada. From my knowledge of the paper industry, I am aware that it is almost always the case that for economic reasons paper mills manufacturing virgin paper will be situated close to the forests from which they obtain timber. In the case of the paper mills referred to in the summary, I have confirmed with a number of the largest paper mills that this is the case
3. Turning to McDonald's paper packaging generally, in December 1993, I prepared jointly with Linda Frason, the Environmental Products Manager at Perseco, a report called 'Paper Packaging Environmental Perspective which dealt with three issues: (1) the estimated quantity of trees McDonald's would require to make paper packaging; (2) McDonald's use of recycled paper for packaging and (3) the quantity of packaging used at McDonald's compared to the quantity used in the delivery and preparation of a similar meal at home. I attach a copy of this summary at "DJK 6".
| date signed: |
June 22, 1993
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| Supplementary statement date signed: |
11 January, 1994
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exhibits: Not applicable/ available
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