WANT TO SHARE SOME DEPO TESTIMONY W/YOU ALL DR. KELMAN

[Guest guest]

12:19:56 20 Q Has anyone -- can you cite to one

21 published peer-reviewed paper that concludes that

22 mycotoxins in an indoor environment could not reach

23 a level to cause human illness besides the ACOEM

24 statement?

12:20:18 25 A The ACOEM statement doesn't say that

318

1 either. I couldn't cite to any paper that says

2 that because it's not true.

3 MR. SCHEUER: Excuse me. Could I have the

4 question and answer read back, please.

12:20:28 5 (Record read as follows:

6 " QUESTION: Has anyone -- can you

7 cite to one published peer-reviewed paper

8 that concludes that mycotoxins in an indoor

9 environment could not reach a level to

12:20:16 10 cause human illness besides the ACOEM

11 statement?

12 " ANSWER: The ACOEM statement doesn't

13 say that either. I couldn't cite to any

14 paper that says that because it's not

12:20:26 15 true. " )

16 BY MR. BANDLOW:

17 Q It could reach sufficient levels in an

18 indoor environment, but it's typically your

19 testimony it has to be extremely high levels?

12:21:04 20 A Well, we can calculate an upper limit what

21 could be present and when the upper limit is too

22 low to cause any adverse effects, then the answer

23 is, no, it's extremely unlikely that it's causing

24 any adverse effects. If you were to get to, say,

12:21:20 25 grain levels of concentration, of course, that's

319

1 part of dose response; that's possible.

2 Q Has anyone replicated and peer-review

3 published the math calculations while concluding

4 human illness from exposure to inhaled mycotoxins

12:21:44 5 in water damaged buildings is highly unlikely at

6 best?

7 MR. SCHEUER: Objection; asked and

8 answered in the prior session of this deposition.

9 I'll permit the witness to answer it

12:21:52 10 again.

11 THE WITNESS: I've never seen those

12 precise words nor would I expect anyone to

13 precisely say the same thing. The idea is

14 certainly there.

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