Document gD5Vk4LEdaeepZJpj2ar8vqrN
Electronically Served 9/22/2017 10:33 PM Hennepin County, MN
27-CV-10-28862
STATE OF M INNESO TA DISTR IC T CO URT FO R THE CO UNTY OF H ENN EPIN FO URTH JUD ICIAL D ISTRIC T
C IV IL A C TIO N NO . 27-C V -10-28862 ST A T E O F M IN N E SO T A , et al. v. 3M C O M PA N Y
EXPERT REPORT OF PH ILIPPE G RAN DJEAN , M D, DM Sc
PREPARED ON BEHALF OF PLA IN TIFF STATE OF M INNESO TA
22 Septem ber, 2017
CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862
27-CV-10-28862
Filed in Fourth Judicial District Court 11/17/2017 7:31 PM
Hennepin County, MN
calculations, the M D H has issued fish consumption advice for bluegill, carp, largemouth bass, northern sm allm outh bass, walleye, and white bass from M ississippi pool 2 and for some species also for the M inneapolis chain o f lakes [18, 24].
2. Breast milk
Recent data support that U.S. children have higher serum concentrations than adults [25, 26]. As a potential contributor, evidence has accum ulated that PFCs are excreted in hum an m ilk [27]. A nalyses o f paired samples o f m aternal serum, cord serum, and m aternal m ilk have demonstrated that PFCs are transferred through the hum an placenta and via hum an m ilk [28, 29]. D uring prolonged breast-feeding, the cum ulated postnatal exposure to PFCs through lactation can be m uch higher com pared to prenatal exposure, especially for PFO A [29], thereby causing additional exposures during sensitive early development. From serial blood samples in young children, a recent study show ed that extended breastfeeding could increase an infant's blood concentrations o f PFC s to several-fold above the m other's [30].
These observations are in accord w ith a 3M -sponsored study on EtFO SE and FC95 (PFOS) carried out in goats, as indicated by an email to Dr. Larry Zobel in early 1998.p The first studies on transfer into m ilk were apparently carried out in 1993, as a docum ent from that tim e states: "There is some prelim inary evidence that in lactating goats PFO S is transferred to milk. It is likely that lactating hum an fem ales w ould also transfer PFO S to m ilk."q Again, it appears that 3M decided not to publish the results o f this study, and it further appears that 3M did not follow up with analyses of hum an m ilk to establish the potential im plications of this discovery.
In a tw o-generation study involving rats published by 3M 's Dr. B utenhoff and coauthors in 2004, pup weights in the highest dose group were consistently decreased throughout the lactation period [31]. This study also found a slight but statistically significant decrease in lactation index (percent viability from day 5-22 post-partum ) for Fi pups. It is not clear w hether these observations w ere due directly to toxicity from PFCs in the milk, or indirectly via deficient lactation, and such concerns w ere apparently not o f interest to the authors. The transfer o f PFCs through m aternal m ilk in animal m odels was finally recognized by 3M colleagues in a 2005 publication [32].
A ccordingly, the recent publications on PFC transfer via hum an m ilk [27, 30] do not represent a discovery, but rather a re-discovery of a mechanism identified by 3M much earlier, in 1993, in studies that 3M did not disclose publicly. The relevance o f the 3M results on PFC transfer via lactation in goats m ust be considered in a w ider perspective. Due to growing concerns about lactational transfer o f dioxins, PCBs, and some pesticides, toxicological studies began to pay attention to this pathway, and in 1976 the W orld Health Organization began a global m onitoring program to m easure persistent pollutants in hum an m ilk [33]. Since a thorough review handbook on hum an m ilk contam ination and health risks was published in 1991, the
p 3MA00906295. Fluorochemical Projects Underway in the Environmental Laboratory. Page 3MA00906295. q3MA10037365, PFOS Disposition, custodian Reagen, William K. Page 3MA10037367.
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CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862