Day 007 - 06 Jul 94 - Page 07


     
     1        A.  That is correct, sir.
 
     2   Q.   To suppliers you emphasise source reduction both so far as
              their purchases and their manufacturing processes were
     3        concerned?
              A.  That is correct, sir.
     4
         MR. JUSTICE BELL:  I hope that reflects -----
     5
         MR. RAMPTON:  When we speak, Mr. Kouchoukos, of source
     6        reduction, are we speaking in terms of volume or of weight
              or of both?
     7        A.  Typically weight and sometimes volume.  When we made
              some changes with foam packaging we are looking for volume
     8        reductions, but most of our packaging reductions are by
              weight.
     9
         Q.   Have I got this right?  Just touching on polystyrene foam
    10        for a moment, the lighter a given volume of polystyrene
              foam, take a cubic foot, which is a measurement of volume
    11         -- you will correct my layman's science if I go wrong,
              will you not -- a cubic foot of polystyrene foam, the
    12        lighter it is, the less foam within that cubic foot?
              A.  Correct, so there will be a lower density, yes.
    13
         Q.   Does that entail that a greater amount in weight of
    14        blowing agent must have been used to produce that effect?
              A.  Yes, more blowing would be used.
    15
         Q.   Does this or these considerations, reduction, recycling
    16        and re-use, have practical constraints on the ground, as
              it were?
    17        A.  Definitely, in terms of source reduction.  As we look
              for source reduction, we definitely cannot impact the
    18        performance of the product.  I will back track a little to
              explain how we evaluate a package.  We look at
    19        environmental performance; we look at crew operational
              performance; that is how the crew is handling and able to
    20        put the sandwich products, french fries, whatever it is,
              into the package effectively; we look at customer
    21        operations; is the customer's ease of use of the package
              good?  Can he get the sandwiches in and out of the
    22        container as well as he might?  The fourth constraint
              would be cost.  We balance those all equally.  There is no
    23        priority of criteria; it is a balance of all of those.
 
    24   Q.   I was going to ask you this, Mr. Kouchoukos:  In your
              relationship with McDonald's, do you feel pressure to cut
    25        corners in relation, for example, to environmental
              performance on account of cost? 
    26        A.  No, I do not think so.  We always balance the optimum 
              or the best environmental impacts we can, given costs, 
    27        given other performance criteria.  It is always a balance.
 
    28   MR. JUSTICE BELL:  The other performance criterion may be
              relevant to cost anyway, may it not?
    29        A.  Source reduction ---
 
    30   Q.   How quickly and easily you can put something in a package,
              things of that kind?

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