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My overall responsibilities within the BPBIF extend to the development of policy and the co-ordination of activity in the industry in the fields related to this action, namely Environmental issues, Recycling, Energy, Health and Safety and Product Legislation.
I have examined the allegations made by Greenpeace (London) and the supporting evidence and have contrasted these with evidence and commercial practise exhibited by McDonald's. From my personnel knowledge and experience I can say that many of the allegations and much of the evidence supporting these allegations is inaccurate and without foundation. In sharp contrast my opinion is that McDonald's have displayed a highly commendable and sensitive approach to the environment blending skillfully commercial and customer needs with a purchasing policy aimed at minimising the environmental impact of their operations. My reasoning is set out in the following which examines the general papermaking practices used and relates these to McDonald's and then to the various allegations.
PAPERMAKING PRACTISE, USA., UK, EUROPE AND SOURCES OF PAPER FOR MCDONALD'S
McDonald's are engaged in legal action consequent upon allegations that the production and disposal of packaging is damaging to the environment. In particular it is claimed 'that the purchasing by McDonald's of many tons of paper most of which is not recycled, contributes to the destruction of trees and forests which causes environmental damage'.
These allegations and supporting evidence address particularly the process of papermaking, the use of chemicals including bleaching the effects of these chemicals and their derivatives upon humans and other factors relating to energy use, yield of paper from wood and paper making operations in general. They are addressed below.
1. The Pulp and Papermaking Process
Wood For Papermaking
Nearly all paper and board is made from either new or recycled woodpulp.
The industry was once based almost entirely on softwoods such as spruce, pine, larch, fir and cedar. Now birch, aspen and other hardwoods occurring in temperate climates are used as an ideal raw material for processing into fluting for corrugated cases as well as printing and writing papers, whilst eucalyptus, originally occurring only in Australia and New Zealand, has been successfully cultivated in other warm climates (eg South America, Spain and Portugal) as raw material for high-quality pulp suitable for a wide range of papers. Nevertheless, softwoods provide longer fibres (average 3mm compared with 1mm for hardwoods) and continue to be used for papers required to have the highest strength characteristics.
Wood Sources
Again practice has changed. Once pulpwood was derived universally from whole mature trees. Today 30-40% of wood used for pulp in the USA, for example, comes from waste left over from sawmills after wood for construction purposes has been taken from the tree and nearly all the pulpwood used in northern Europe could be classed as secondary cuttings, for example, thinnings extracted from the forest so that the remaining trees can grow to healthy maturity.
Diminishing Resources
Trees are not cut solely for papermaking. Indeed, trees cut for Industrial purposes such as construction, fencing, posts and spars and particle board, are replaced in greater concentration. However, where one tree grew in the past, planting programmes ensure that two or three will grow in replacement. In the developed world advantage is taken of the massive research which has been devoted to developing the best strains and to planting and conservation techniques likely to produce the healthiest trees. The whole process can be regarded as one of sowing and harvesting a crop like wheat and barley, only sown and reaped at much longer intervals, though some strains can be cut as frequently as every seven years under optimum growing conditions .
The destruction of rainforests in South America and Indonesia is an ecological disaster, but has nothing to do with the papermaker. Rainforest timbers are not suitable for papermaking and are not used in the Western World. Although 'commercial' trees are currently growing in increasing areas previously covered by rainforest, the original growth was destroyed long ago by shifting farmers or for other reasons totally unconnected with the paper and board industry.
At current rates of usage, trees for papermaking and other industrial uses will last forever. This is because more wood is growing now than is being cut down. Sweden, for example, now has reserves of wood greater than a hundred years ago despite the enormous growth of wood usage during the last fifty years. Forest stocks are being further conserved by the rapidly increasing use of recycled waste paper for the manufacture of fresh paper and board. Over 30% of the world's papermaking fibres now derive from wastepaper, and in the UK the figure is over 60%.
Wood is one of the very few raw materials used by a major industry which is infinitely self-renewing. Even if world usage were to increase sharply - and future demand for wood as a fuel by growing populations in third- world countries is difficult to forecast there is no reason why plantings should not be increased to meet the demand. The UK depends heavily on imports to cover her timber needs since the percentage of land under forest is, at some 10%, one of the lowest in the world. The reduced need for food production in the EC has given scope through the 'Set Aside' programme for increased levels of tree planting which bring attendant commercial and environmental advantages.
Woodpulp as a Raw Material for Paper
Cellulose fibre in the form of woodpulp is the main raw material for papermaking. No two species of tree produce the same grade of fibre. In fact, the same species grown in different parts show different fibre properties. For example, the slow growing pines of Northern Europe produce long fibres which give strength and long life; essential for packaging and high grade printing papers. The shorter fibres from rapidly growing deciduous tree from closer to the Equator are lower in strength, but have other qualities suitable for different products. The papermaker utilises these characteristics to produce diverse product ranges.
Some of the pulp properties depend upon the process used to separate the fibres from the timber. There are three main processes for this:
- Mechanical (or Groundwood) - Chemical - Combination
Mechanical Pulp
This process uses all the input timber except for the bark and is very cost effective. The timber log is chipped, and these are then put through a refining process (essentially grinding) to separate the fibres. Chemicals are not used, but the drawback is that the energy requirement for refining is high and can be compensated only in part by using the bark as fuel. The other disadvantage of this method of pulping is that the wood fibres are not reduced to their basic cellulose structure and are still very much "wood". All the natural tree substances are retained in the pulp - sap, sulphur compounds, sugars and lignin (which binds the fibres together).
The process does have considerable offsetting advantages. These relate to the fact that mechanical pulping provides a good yield from the pulpwood: 90% or above and the investment costs for mechanical pulp mills are relatively low when compared with other pulp mills. Mechanical pulp is well-suited for 'bulk' grades of paper, such as newsprint and packaging boards. It can, moreover, be bleached with peroxide for use in higher, value-added products. It has, however, lower strength characteristics than softwood chemical pulps and, because it retains most of the lignin which reacts with ultra-violet light, can 'yellow' when exposed to bright light.
Chemical Pulp
The majority of chemical pulp produced in the world today is based on one of two processes: sulphate or sulphite.
The larger proportion of chemical pulp is made by the alkaline kraft or sulphate process which uses caustic soda and sodium sulphate to 'cook' the woodchips. In the unbleached stage, a dark brown, but very strong pulp results. This can, however, be bleached to a high brightness using chlorine or, more frequently now, oxygen and chlorine dioxide. The thrust of this is eventually to eliminate the use of chlorine.
The acid, or neutral sulphite mills produce easily-bleached pulps which today are, for the most part, bleached with hydrogen peroxide. These pulps are fulfilling today's increasing demand for chlorine-free products in the disposables sector and, now, also in printing and writing papers.
The yields in both chemical processes are much lower than in the manufacture of groundwood at around 50%. This is because the lignin is completely dissolved and separated from the fibres. However, the waste lignin from the kraft and some sulphite processes can by burnt as a fuel oil substitute. In modern mills, recovery boiler operations and the burning of bark or other reside in a controlled manner make the chemical pulp mill a net energy producer which can often supply power to the grid, or steam to local domestic heating plants.
Combination Pulps
Thermo-Mechanical-Pulp (TMP) and Chemi-Thermo-Mechanical-Pulp (CTMP) are a combination of the mechanical and chemical processes. De-barked logs are chipped in both, then heated to extreme temperatures to soften them before passing through grindstones for mechanical reduction to fibres. The difference is that chemicals are sprayed onto the chips in the CTMP process to reduce the undesirable effects of the retained natural wood substances. The main disadvantage of this form of pulping is the high energy demand. Both processes give high pulp yields, but papers made from them have inferior ageing qualities compared with those made from chemical pulps.
Pulp Bleaching
Woodpulp is bleached to convey certain properties. The bleaching process:
- adds brightness with' loss strength;
- improves absorption,~(important in products such as toilet tissue) and fibre flexibility;
- eliminates substances such as fatty acids that can cause an unpleasant taste or odour (important in food contact);
- eliminates wood residues;
- creates resistance to ageing.
If the consumer requires these qualities they will not be available in an unbleached product, nor in a recycled product. Indeed, purchasing paper products made from recycled fibre does not guarantee 'chlorine free' paper because it is impossible to tell where the reclaimed waste paper came from. Although no chlorine bleaching is carried out in the UK, chlorine bleached pulp and paper is imported and this eventually will appear in recycled paper.
Dioxins and Pulp Production
It is a matter of scientific fact that the uncontrolled process of bleaching woodpulp using chlorine will give rise to the production of organochlorines and of certain but minor quantities of polychlorinated dibenzo-para-dioxins (PCDDs) and polychlorinated dibenzofurans (PCDFs). These latter are usually linked together and commonly referred to as 'dioxins'. Dioxins have achieved notoriety following heavy and accidental exposures such as that at Seveso in Italy and its use as a component of the defoliant Agent Orange used by the US in Vietnam.
Continuous development has however, shown that the formation of 'dioxins' in chlorine based pulping may be easily avoided by decreasing the molecular chlorine multiple (the ratio between the charge of molecular chlorine and the amount of lignin in unbleached pulp). Thus the distinction between bleached and unbleached now has little meaning in the context of dioxin. A further development was the elimination of certain defoamers (chemicals used to eliminate the foaming action of the water/pulp liquor in pulp plants) which could act as precursors to dioxin formation. These two factors have effectively eliminated 'dioxins' from the pulping process. Indeed, all modern pulp mills today employ these and associated methods which in combination also minimise the formation of organochlorines. Because of this, pulps and papers have dioxin contents at or below the level of detection (much less then 1 part in a trillion- 1 ppt may be linked to a comparison between the thickness of a credit card and the distance from the earth to the moon). This generally applies to suppliers of pulp products to McDonald's
With regard to human assimilation of dioxins via contact with paper and board used in the packaging and transport of food, the implications are contained in the definative UK report Dioxins in the Environment published in 1989 as Pollution Paper No. 27 by the department of the Environment. The report recommends that methods, other than chlorine bleaching, be developed for pulp as a way of reducing background environmental dioxin level. Indeed, in the years since then the industry has employed two approaches: the elimination of chlorine and the processes referred to earlier which prevent the formation of dioxin. In the study no evidence could be found that dioxins in food contact materials significantly contributed to human dietary intake of dioxins. We understand that no contrary evidence has emerged since the publication of the report.
Extensive research and widespread consultation was performed by the UK Government when preparing the above Pollution Paper. In particular, the question of human toxicity arising from dioxins exposure from all sources was addressed in great detail and the Paper's conclusions again represent the definitive current position. Although there was considerable evidence to suggest that dioxins could have carcinogenic and immunotoxic effects on certain animals, it was concluded that the metabolic system of humans conferred resistance to dioxins. The Paper was, therefore, unable to establish a link between human dioxin intake and human cancer and immune system deficiencies. Thus, the substantive point of evidence in support of the defendant with regard to dioxin is completely refuted.
The Papermaking Process
Once the pulping process is complete, the paper manufacturing process is virtually identical whether using this Virgin fibre or recycled fibre.
The prepared pulp is mixed with water, screened and passed onto an endless open mesh wire. Draining the water through the wire causes the fibres to align and bond together. Chemicals known as retention aids, are used to facilitate this process and defoamers are used as well as to reduce the foaming effect from cascading water at all points in the system. Biocides and slimicides are also used to reduce organic growths in the pipework systems. These have short term activity, exceptionally days, but periods vary. These contain small proportions of pesticide based substances. Manufacturers must comply with the Control of Pesticides laws, but these do not apply to paper mills as the strengths used are below the legal minima.
The remaining significant addition is of dyes. The past generations of benzidene based substances have been banned in UK for two decades as posing unacceptable human risks. Similarly, the reactive dyes that have been questioned in other industries are not suitable for papermaking. The need for a water miscible dye that has the characteristics of fast and permanent attachment to cellulose fibre means a specific substance, but with no environmental concerns except for the visual effect of residual colour.
Many of the earlier generation of problems have been removed by the shift from acid to neutral water systems; ie around pH7. This has also simplified the surface coating materials. These range from starch based compounds for simply providing a sized surface to avoid the Blotting papers effect, to aqueous based compounds for high definition, high speed printing purposes. Solvent based compounds are used for coating some specialised products for such as damp resistance in materials storage or electrical resistance papers, but environmental protection costs mean these being limited to very specific purposes.
After formation the paper is pressed to remove much of the residual water and the paper is dried by being passed through banks of steam heated cylinders. This completes the basic process and the paper is wound into a reel for later cutting and converting into the finished paper product.
2. The Disposal of Waste in Papermaking Four main types of waste arise from the papermaking process.
These are:
- product off cuts and other similar residues - boiler plant residues - aqueous effluent - solid wastes
These are dealt with as follows.
Product occurs other residues
Mills will seek to use their own "broke"; the term for these residues. Traditionally, the industry has recycled these as a small proportion of even "virgin" products. Where this is not possible because of colour or coating they may enter the waste merchant chain and be purchased by another mill as raw material. Landfill for this material is a last resort.
Mills using recycled material face greater quality control problems and will have higher quantities of unusable materials extracted during processing. They may be able to dispose to a mill making lower quality grades, but landfill is increasingly unavoidable for these wastes.
Boiler plant residues
The industry is no different from any other with power or steam generation plant. there are emissions to atmosphere from fossil fuels and ash residues where coal is used. As with others, the trend has been to gas in particular but with oil burning support capability.
Aqueous
The water based production process means that aqueous treatment is a major factor for any mill. Some have their own treatment plant with consented discharge to surface waters, whilst others operate commercial trade effluent treatment contracts with th water service companies. The requirements for improved treatment started with the 1974 Control of Pollution Act in UK and was given further impetus with the formation of the National Rivers Authority under the 1989 Water Act. Mills discharging to surface face increasingly stringent and diverse standards covering both biological and chemical criteria. In general this will not be achievable without both primary and secondary treatment capability. Recycling mills face more difficulties due to contaminants in the incoming materials.
The pressure to use less water means a continuing trend to "close" systems; ie to recycle water. In broad terms this increasing efficiency means the UK industry now uses only some 30% of the water it used 20 years ago. However, this means greater control over the internal mill water quality as it becomes more contaminated and there is a point when more chemicals have to be added. This will add to the problems of few treatment, so totally closed systems are not yet practical. These trends are similar throughout the western world.
Solid Wastes
Part of the role of effluent treatment systems is to settle out solids, so mills have these residues to deal with. As a guide a mill with 50000tpa production with a 70% yield will have a minimum of 22000tpa of such waste. Some new products are being developed to utilise these wastes but the bulk will go to landfill until incineration becomes an acceptable alternative in Europe. In general the amount of waste generated per tonne of paper produced has improved with technology over the last decade. However, mills based on recycled materials generate more solid waste than virgin mills but in contrast by their operation effectively divert material from landfill, the whole having an offset leaving the balance in favour of recycled mills.
3. Enemy Use in Paper and Board Making
Energy is consumed at two principle points in the papermaking cycle, the pulp manufacturing stage and the paper manufacturing stage.
Pulp manufacture produces a number of by-products such as bark and pulping liquor which can be incinerated within the mills power plants. This has the effect of making pulp manufacture an operation which requires no net input of fossil fuel energy.
In contrast, paper manufacture has no combustible by-products and therefore requires a net input of energy. In the UK, this figure is around 25 GJ/tonne of packaging papers and boards. Our evidence shows dearly that energy use during making is not dependent on the amount of recycled fibre in the paper.
4. Wood YIeld for Papermaking
Wood for manufacture of papers relevant to McDonald's arises principally in the European Economic Area (EEA) and in the USA. The wood yield for papermaking in these areas Is as follows.
European Economic Area
In 1992 the pulp producing mills of the European Economic Area used 118.5 million cubic metres of pulpwood of which 27% was hardwood. From this was produced 31.0 million tonnes of woodpulp {average yield 3.82 m3/tonne pulp).
Allowing for exports of pulp (deduct) and imports of pulp (add) the EEA 'apparent' consumption of pulp was 36.4 million tonnes. Actual consumption of pulp was recorded as 36.2 million tonnes and this, combined with 24.9 million tonnes of wastepaper and 9.5 million tonnes of other pulps and materials such as clay etc., gives a total EEA raw material input fibre of 70.7 m tonnes. From this was produced 63.6 million tonnes of paper and board and of this, 40% (25.7 m tonnes) was packaging paper and board of all types.
These figures are supported by the Tables in Annex 1.
USA
The US used 103.891 000 cords of pulpwood (376.6 million m3) in 1992 to produce 63.96 million short tons (2000 lbs Imperial) of woodpulp, of which 58.02 million short tons was papermaking pulp.
Recorded consumption of woodpulp was 62.0 m tons and with 25.4 m tons of recovered paper a total fire input of 87.4 m tonnes was used to produce 82.9 m tonnes of paper and board' of which 51% was paperboard of all levels, chiefly for packaging - much kraft liner w~qEthe~atter total Is exported. V
These figures are supported by the Tables in Annex 2.
5. The Proportion of Waste Recovery for Recycling
The paper and board has a long and successful history of recycling. Recovery of wastepaper for recycling has grown substantially in virtually all countries in the last 10 years and is forecast to increase further in response to the need to conserve resources and reduce landfill, though the conservation of resources is not in question in the US and Europe since pulpwood requirement even for virgin fibre paper grades are secured from sustainably managed forests.
Comparative figures showing the progress made in the last 10 years period are given in Table 1 for the European Union, the United States and the UK and Germany separately.
The figures in Table 1 are overall figures for paper and board. For packaging grades, the utilisation rates are generally higher and a study carried out by the European Confederation of Pulp and Paper Industries (CEPAC;) in 1991 revealed that the average utilisation of wastepaper in packaging grades produced in 5 EC countries in the study in 1990 was 91%; a more detailed study in the UK for 1992 showed a utilisation rate of 94% in packaging compared with an overall average utilisation of 60% in all paper and board.
All countries have recovery targets for recycling. Indeed, the targets for which political agreement has recently been reached in Europe regarding the EC Packaging & Packaging Waste Directive indicate that a minimum of 25% and a maximum of 45% of packaging waste should be recyded. The proposals in the UK nearing completion call for recovery of between 50 and 75% of waste including options for incineration with energy recovery. In many of their specifications, McDonald's seek 100% recycled products and even specify high levels in their Food contact papers. If all packaging users were to take the same responsible attitude towards creating the end use markets, there would be no difficult in achieving these national and European targets.
6. Recycling process for paper and packaging
Essentially the papermalcing process (once the diluted fibre has been put on to the papermalcing machine) is the same whether it be virgin fibre or recycled fibre. The difference is that wastepaper will require additional cleaning and refining processes involving an Ezra energy requirement.
Energy Consumption
Comparisons are often made by others that increased recycling leads to a reduction in requirement but this is only true if comparing a mill using virgin pulp from a non-integrated mill with a mill making a waste-based product from recycled fibre. At an integrated mill, there is a net export of energy and a saving on fossil fuel. A recycled mill will however be a net consumer of fossil fuel energy. The main reason that recycled paper is economic and an important alternative is that sometimes the fibre source is more economic and it uses the fibres to exhaustion even though in the process additional fossil fuel energy is consumed.
Waste disposal
The use of wastepaper reduces landfill disposal, but if takern to the extreme could result in the under optimisation of forest areas and an increase in solid waste emissions resulting from plant and power station residues. It is not feasible to say that all products should be made of recycled fibre; a balance has to be maintained.
The debate at national and European level is currently centred on where that balance should be struck, the extremes being instanced by Germany, where collection has reached proportions causing environmental damage, as compared with the more measured approach in other countries who understand better the need for increased end-use markets. Nevertheless it is true that substantially more recycling can be achieved without resulting in the extreme economically and environmentally unsound limits proposed in Germany. It is a question of provideing the balance between end-use requirements and material recovered.
When using virgin fibre, there is no solid waste to be disposed of since the raw material is pure. When using wastepaper, however, there is always extraneous matter which will involve the creation of solid waste. If the wastepaper is lower grade and contains many contraries - or has heavy coatings or printing which are disposed - the proportion of solid waste will be higher than for a clear uncoated waste which is uncontaminated.
Where solid waste is produced it will generally go to landfill, but increasingly, mills are carrying out research to find useful end-use and some sludge is already being incinerated for energy recovery and used for soil enrichment.
Chemicals used
There are upwards of 50 chemicals used in the papermaking process and these would be much the same whether for a recycled or virgin fibre grade. Their use is strictly controlled by national and international legislation.
7. The Precticable Proportion of Recycled Fibre to Original Fibre
The use and proportion of wastepaper in particular paper and board products is determined by many factors including consumer demand, economic viability and environmental considerations and the practical proportion of recycled paper which can be incorporated in a product can be any figure from O to 100% depending on the product and its end-use.
For some packaging grades the use of wastepaper not only helps reduce landfill but in the case of corrugated board for instance is mostly a more economic raw material than its virgin fibre counterpart and to this extent most papermakers will use as much wastepaper furnish as possible consistent with the users specification and a fitness-for-purpose product.
For low grade packeing and some newsprint and tissue grades for example, a mill mid use between 110 - 130 tonnes of wastepaper to produce 100 tonnes of finished paper which would be "100% recycledn. For a high security bank note paper which has a strict strength and quality requirements, the paper would be made from 100% virgin Sbre requiring slightly in excess of 100 tonnes of bleached woodpulp to make 100 tonnes of paper. Between these extremes it is possible to incorporate varying proportions of wastepaper which will depend on customer requirements and suitability for purpose.
Whilst there are no European regulations which forbid the use of wastepaper in food contact grades of paper and board, the producer has the responsibility of ensuring the products are safe and conform to health and safety regulations.
Whilst some manufacturers can satisfy themselves that their sources of waste can be closely monitored and guaranteed clean, and will thus be confident to manufacture a paper or board of 100% waste, others will prefer to ensure totally the safety of the product by having a layer of virgin fibre material on the surface which comes in contact with food. McDonald's prefer to choose this second route as an absolute guarantee of the health and safety of their folding carton material (such as that used for chips, apple pies and Happy Meals, which has a 72% recycled content with a thin outer layer of virgin material. Bearing in mind that there are no regulations in Europe, McDonald's appear to be in the vanguard of those showing environmental concern and their approach is to be commended rather than cause concern since their objective is to maximise the use of recycled fibre whilst maintaining the highest standard of consumer protection.
Relative cost of recycled fibre
The relative costs depends very much on the grade of wastepaper and are in any case difficult to compare because the use of recycled fibre entails additional processing costs which are variable dependent on the grade and end-use in addition to the cost of the actual material itself.
The current cost of collecting, sorting and transporting the very lowest quality of wastepaper is in the region of £30 - 35 per tonne. In Germany, the true costs are many times higher due to rigid legislation enforcing uneconomic collection levels and banning landfill and incineration. Cost to the paper mill may be zero or even negative, however since the cost is being borne by other parts of the chain i.e. the consumer.
Virgin pulp prices also vary considerably depending on the process but at the lower end, the price for a mechanical unbleached grade the average is £195 per tonne.
At the other end of the scale are high grade so called "pulp substitutes grades of wastepaper for which the cost in the UK currently varies between £150 and 180 per tonne. The price in the UK for Northem Bleached Softwood Kraft pulp (which is the marker grade) is £270 per tonne.
For the production of paper and board products likely to be used in contact with food the requirement would be for the highest grades of wastepaper to ensure the necessary degree of quality. Wastepaper from the conversion processes are already being collected virtually to their limit, and thus additional supplies of quality material are only available as post consumer waste which is widely dispersed using much energy to collect and to clean to the required standard. Thus the cost of usmg high grade recycled waste is often likely to exceed that of virgin fibregrades for such products and in these later circumstances, a specifier is accepting a financial cost in order to satisfy consumer demand and concerns by customers for recycled products. McDonald's, by specifying a 72% recycled content even in htese food conract applications accept these extra costs in satisfying consumer concern.
8. Suppliers of Paper and Packaging to McDonald's
McDonald's source their products principally from the US. Details of suppliers are attached in Annex 3. As regards Europe, a provisional and incomplete list is given in Table 2. It is clear from sample contracts with these suppliers that McDonald's apply the highest standards and that suppliers in general operate to high environmental standards.
CONCLUSION
Allegations have been made concerning the commercial operations of McDonald's and the deleterious effect that these may have on the environment. These operations have been examined and evidence for and against McDonald's has been studied. In addition, the purchasing policy of McDonald's in relation to the high substitution of recycled paper products for plastic and virgin paper products has been subjected particular scrutiny.
The allegations refer particularly to the purchasing by McDonald's of paper 'most of which is not recycled' yet the evidence from McDonald's and from examination of their suppliers tends to indicate to the contrary. Indeed, the approach by McDonald's to the adoption of recycled papers where possible is highly commendable. Moreover, through this approach McDonald's are clearly in the vanguard of recycling and ahead of many other companies and certainly ahead of the yet to be finalised requirements of the forthcoming EC Directive on Packaging and Packaging Waste.
As regards the residual virgin paper products these appear essentially to be at a minimum and consistent with a very high standard of hygiene, responsible food contact and customer care. As regards the pulp and papermaking processes involved examination of supplier data coupled with spot interviews with suppliers indicates that most, if not all are adopting the latest technology and/or process control thereby practically maximising yield while minimising energy use and emissions and also preventing the formation of dioxins in the pulping process.
Allegations were made regarding the carcinogenic effects of dioxin and effects on the human immune system. These allegations are completely without foundation and the principal source of evidence for this is in Pollution Paper No 27 published by the UK Department of Environment.
Further allegations were made regarding the destruction of trees and forests thereby causing environmental damage. Papermaking is not the only process using timber and therefore it is difficult to assess any magnitude of culpability attributable to McDonald's even if the destruction allegations was well founded. However, since all western pulping and forestry operations arc conducted on a sustainable basis the allegation is without foundation. Indeed, there is ample evidence to show that sustainable forests are growing rather than reducing in size due in part to the worldwide papcrmaking operations fostering free planting programmes considerably in excess of cutting requirements.
In summary, I can find little or no substance in the allegations nor any particular evidence which would warrant the singling out of McDonald's to be the particular subject of the allegations made.
| date signed: |
January 13, 1993
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exhibits: Not applicable/ available
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