Duplicated from a previous post:
Actual 3M deposition testimony from 7/24/20…
Q. And based on what you know, sir, about the persistence of PFOS, the overwhelming majority of every molecule of PFOS that's ever been manufactured by 3M is still in existence, correct?
A. That's quite likely. I like your verbiage, the overwhelming majority, that's probably correct. I don't have any actual factual data on that, but that would be my supposition, based on what I know about PFOS.
Q. Yes, sir. So based on what we know about the manufacturing and based on what we know about its persistence, it's just a matter of mathematical probability, that if we find a molecule of PFOS in the environment, particularly here in the United States, more likely than not, 3M is the source; is that fair?
A. That's more likely than not. I know that there's a company in Italy that has manufactured PFOS. There might be other people who have, but I would say just on a proportional basis it's more likely than not.
Q. It's almost certainly true on a proportional basis, just again, from a mathematical perspective, it's most certainly true that if you find a molecule of PFOS in the environment, particularly here in the United States, it's from 3M, fair?
A. That's fair, and one can look at the branching profile of it and get a good idea of that as well.
Q. And I know you probably think I'm belaboring the point, but, in your view…the source, I guess, based on mathematical probability, if we find PFOS in human br---t milk, more likely than not it's from 3M, fair?
A. Yeah. Again, as I said, I'm not going to disagree with that premise, so that's fair.
Q. Okay. And, sir, you're aware that PFOS has been detected in arctic mammals?
A. Yes, I'm certainly aware of that…
Q. And it's famously discussed that you can find PFOS in polar bear blood, correct?
A. Right, that's correct.
Q. And I know you feel like I'm belaboring the point, but there's no question in your mind that the source of PFOS in the polar
bear is from 3M, right?
A. I -- again, it's certainly more likely than not, yes.
Q. Rivers and streams, you're aware that PFOS has been detected and reported in rivers and streams?
A. Yes. Yeah, I have awareness of that, mm-hmm.
Q. And you're aware that PFOS has been detected in ocean waters, both the Atlantic and the Pacific?
A. Yes.
Q. And you're aware that PFOS has been detected in drinking water in the United States and elsewhere, correct?
A. That's correct.
Q. And you're aware that PFOS has been detected in human blood?
A. I'm aware of that, yes.
Q. You're aware that PFOS has been detected in umbilical cord blood as well, correct?
A. That's correct.
Q. It has been detected in shellfish?
A. Yes, there's a question there, yes.
Q. Has it been detected in fish?
A. Yes.
Q. It's been detected in indoor house
A. Yes.
Q. And daycare dust, right?
A. Yes, based on the paper by…, yes.
Q. And I apologize, I'm just going to make this little movie clip, and we'll move on. Has it been detected in outdoor air?
A. Yes.
Q. It's been detected in human br---t milk as well, correct, sir?
A. That's correct.
Q. And last but not least, it's been detected in polar bear blood, right?
A. As well as other arctic mammals, yes, mm-hmm.
Q. Yes, sir. And each and every one of these media all around the world…the source of PFOS is more likely than not 3M, correct?
A: …Yes, I mean, I -- other than the fact that there might be some manufacturing, I think that more likely than not, the source is 3M, yes.