Day 075 - 17 Jan 95 - Page 23


     
     1        would not be able to conclude from that that there were
     2        more items emanating from McDonald's than from other
     3        sources in total across that kind of range that you are
     4        talking about in that way.  I mean, the one guess that
     5        I would hazard is that you almost certainly would find more
     6        Coke cans than you would find anything else.
     7
     8   MR. MORRIS:  Would you say that McDonald's items, if you had
     9        some artificial, you know, five categories of companies and
    10        whatever, they would be in the top one or two per cent of
    11        company sources?  Coke would be at the top maybe,
    12        McDonald's would be up there at the top somewhere,
    13        honestly?
    14        A.  Yes, but I would want to qualify that to say that my
    15        guess is that in relationship to the number of outlets --
    16        that is the kind of responsible way in which you have to
    17        look at it, not just in total numbers, but in percentage --
    18        then the figures would be quite different.
    19
    20   Q.   Their outlets are about 550 but Coke could be brought from
    21        maybe 20,000 outlets in this country?
    22        A.  That is correct.
    23
    24   Q.   So, in terms of volume per outlet McDonald's would be well
    25        above any other company?
    26        A.  I am not prepared to say that.
    27
    28   MR. JUSTICE BELL:  That is not how I interpreted your last
    29        answer, I must say.  It might redress the balance with
    30        Coke, but with something else where there are much less
    31        outlets, the balance would swing the other way; that is
    32        what you are meaning to say, is it not?
    33        A.  Exactly, yes.  And there is a very different set of
    34        circumstances anyway in the nature of the businesses
    35        concerned, because all the evidence is that because
    36        McDonald's have the control over their outlets in a way
    37        that others do not, they are able to exercise control and
    38        do something about it in a way that other companies cannot
    39        anyway, so I think that is the more important point to be
    40        made.
    41
    42   MR. MORRIS:  You saw those photographs of environment/index.html">litter ---
    43        A.  Yes.
    44
    45   Q.   -- in a street some distance from McDonald's, yes, which
    46        you define as something between standard (C) and (D)?  You
    47        said that a Street Litter Notice can only have an effect
    48        within a certain distance of an outlet?
    49        A.  Yes.
    50 
    51   Q.   Do you think McDonald's can be said to be responsible for 
    52        environment/index.html">litter that is dropped by customers too far away from its 
    53        environment/index.html">litter patrol?
    54        A.  I do not think so, no.
    55
    56   Q.   In your experience, would it be fair to say that a lot of
    57        McDonald's environment/index.html">litter does get dropped too far away from their
    58        patrols to be responsible for?
    59        A.  Yes, because I think the distance over which people or
    60        the length of time that people take to consume food on the

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