On December 10, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Patsy Young,
and
Aventis Inc.,
Avon Products, Inc.,
Block Drug Company, Inc.,
Block Drug Corporation,
Brenntag North America, Inc.,
Brenntag Specialties, Inc. F K A Mineral Pigment Solutions, Inc.,
Charles B. Chrystal Company, Inc.,
Chattem, Inc.,
Colgate-Palmolive Company,
Cyprus Amax Minerals Company,
Cyprus Mines Corporation,
Glaxosmithkline Llc (Sued Individually And As Successor-In-Interest To Block Drug Corporation, Successor-In-Interest To The Gold Bond Sterilizing Powder Company A K A The Gold Bond Company And As A Successor-In-Interest To Novartis Corporation And
Novartis Consumer Health Inc.),
Gsk Consumer Health, Inc. F K A Novartis Consumer Health Inc. F K A Ciba Self-Medication, Inc.,
Insight Pharmaceuticals Corporation, A Subsidiary Of Prestige Brands Holdings, Inc.,
Insight Pharmaceuticals Llc,
Macy'S Inc. F K A Federated Department Stores, Inc.,
Novartis Pharmaceuticals Corporation,
Prestige Brands Holdings, Inc.,
Prestige Consumer Healthcare Inc. F K A Prestige Brands, Inc.,
Sanofi-Aventis U.S. Llc,
Sanofi Us Services, Inc.,
Whittaker Clark & Daniels, Inc.,
for Torts - Asbestos
in the District Court of Erie County.
Preview
FILED: ERIE COUNTY CLERK 03/17/2023 08:48 PM INDEX NO. 815818/2020
NYSCEF DOC. NO. 284 RECEIVED NYSCEF: 03/17/2023
EXHIBIT 75
FILED: ERIE COUNTY CLERK 03/17/2023 08:48 PM INDEX NO. 815818/2020
NYSCEF DOC. NO. 284 RECEIVED NYSCEF: 03/17/2023
MASTER EXHIBIT 124
FILED: ERIE COUNTY CLERK 03/17/2023 08:48 PM INDEX NO. 815818/2020
NYSCEF DOC. NO. 284 RECEIVED NYSCEF: 03/17/2023
f.:\ Taylor&.Francis
~ r .. -N"''~'<,.......r
Inhalation Toxicology
International Forum for Respiratory Research
ISSN: 0895-8378 (Print) 1091-7691 (Online) journal homepage: b.llp://www.tandfonllne.com/loi!liht20
Letter on: "Cosmetic talc as a risk factor for pleural
mesothelioma: a weight of evidence evaluation of
the epidemiology"
Dario Mirabelli
To cite this article: Dario Mirabelli (2017) Letter on: "Cosmetic talc as a risk factor for pleural
mesothelioma: a weight of evidence evaluation of the epidemiology", Inhalation Toxicology, 29:8,
341-341,001:10.1080/08958378.2017.1385114
To link to this article: http://d x.doi.org/10.1080/08958378.20 17.1385114
m Published online: 17 Oct 2017.
~' Submit your article to this journal 8'
W!! Article views: 11
~
~
.... View related articles 8'
(I)
'-"""
View Cross mark da ta 8'
Full Terms & Conditions of access and use can be found at
http://www.tandfonline.com/action/jou rnallnformation?journa1Code= iiht20
Download by: [NS LIJ HS Libraries] Date: 23 October 2017, At: 14:50
FILED: ERIE COUNTY CLERK 03/17/2023 08:48 PM INDEX NO. 815818/2020
NYSCEF DOC. NO. 284 RECEIVED NYSCEF: 03/17/2023
..
INHALATION TOXICOLOGY, 2017
VOL 29, NO. 8, 341 C\
~
Taylor & Francis
Taylor&Frand1Group
https://dol.org/1 0.1080/08958378.2017.1385114
LETTER TO THE EDITOR
Letter on: 11Cosmetic talc as a risk factor for pleural mesothelioma: a weight of
evidence evaluation of the epidemiology"
Sir, wide geographical variation, and Italy is no exception
(Marinaccio et al., 2012). Piedmont incidence rates reflect
Finley et al. (2017) reviewed the evidence regarding asbes- wide-spread occupational exposures to asbestos: from the
tos-related cancers among talc miners and millers, finding Balangero mine, to different plants producing asbestos-
no mesothelioma case in published relevant cohort studies. cement materials, asbestos textiles, asbestos-based brake and
The Piedmont Registry of Malignant Mesotheliomas (RMM) clutch linings, railway carriages and other rolling stock
is the regional operating center of the Italian National materials. A large part of the Italian asbestos industry was
Mesothelioma Registry (Marinaccio et al., 2012). In 2007, located in Piedmont, with the exception of course of ship-
after the mortality follow-up by Coggiola et al. (2003) had yards. Therefore, pleural mesothelioma incidence rates for
been completed, we registered a case of pleural mesotheli- the Piedmont population are not the result of "background,
oma (a man, aged 79) who reported to have been employed exposures.
as a maintenance worker from 1947 to 1957 at the Talco
and Grafite talc mill. Maintenance workers might have
incurred exposure to asbestos for reasons different from Disclosure statement
asbestos contamination of talc, which has been considered No fmancial interest or benefit has arisen from the present work.
to be absent in the Val Germanasca talc mines (Rubino
et al., 1976); however, it is worth mentioning that low-level
exposure to airborne asbestos fibers was indeed reported by Funding
Rubino et al. (1976). No funding has been received for the present work.
RMM publishes and periodically up-dates mesothelioma
incidence statistics for Piedmont. Age-standardized inci-
dence rates in men increased from 2. 7 in 1990-1994 to 6.4 References
per 100,000 person-years in 2010-2014 (standard: European Coggiola M, Bosio D, Pira E, et al. (2003). An update of a mortality
population 27). Depending on how person-years were dis- study of talc miners and millers in Italy. Am J Ind Med 44:63-9.
tributed by calendar period of observation in the Italian Finley BL, Benson SM, Marsh GM. (2017). Cosmetic talc as a risk fac-
cohort of talc miners and millers, 2004 rates may have tor for pleural mesothelioma: a weight of evidence evaluation of the
epidemiology. Inhal Toxicol 29:179-85.
under- or overestimated the expected number of cases. Marinaccio A, Binazzi A, Marzio DD, et al. (2012). Pleural malignant
Under- or overestimation may have also derived from using mesothelioma epidemic: incidence, modalities of asbestos exposure
age-standardized instead of age-specific incidence rates, and occupations involved from the Italian National Register. lnt J
depending on the age-distribution of person-time in the Cancer 130:2146-54.
cohort. As the expected number of pleural cancer deaths in Rubino GF, Scansetti G, Piolatto G, Romano CA. (1976). Mortality
study of talc miners and millers. J Occup Med 18:187-93.
Coggiola et al. (2003) was 1.8, the 2.8 figure in Finley et al.
(2017) table 1 is likely to be an overall overestimation.
Dario Mirabelli
These observations do not change the lack of excess
Unit of Cancer Epidemiology, CPO Piemonte and
mesothelioma deaths in the Val Germanasca cohort, but
University of Turin, Turin. Italy
suggest that the difference between observed and expected
cases might be smaller than Finley et al:s estimate. I, lastly,
e
dario.mirabelli@cpo.it
want to warn about the interpretation of the "expected,
Received 14 July 2017; revised 3 August 2017;
number of cases. Using regional reference rates may be in accepted 20 September 2017
general a reasonable epidemiological practice, but conditions
such as pleural mesothelioma are well known to have very
Preview
FILED: ERIE COUNTY CLERK 03/17/2023 08:48 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 284 RECEIVED NYSCEF: 03/17/2023 EXHIBIT 75 FILED: ERIE COUNTY CLERK 03/17/2023 08:48 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 284 RECEIVED NYSCEF: 03/17/2023 MASTER EXHIBIT 124 FILED: ERIE COUNTY CLERK 03/17/2023 08:48 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 284 RECEIVED NYSCEF: 03/17/2023 f.:\ Taylor&.Francis ~ r .. -N"''~'<,.......r Inhalation Toxicology International Forum for Respiratory Research ISSN: 0895-8378 (Print) 1091-7691 (Online) journal homepage: b.llp://www.tandfonllne.com/loi!liht20 Letter on: "Cosmetic talc as a risk factor for pleural mesothelioma: a weight of evidence evaluation of the epidemiology" Dario Mirabelli To cite this article: Dario Mirabelli (2017) Letter on: "Cosmetic talc as a risk factor for pleural mesothelioma: a weight of evidence evaluation of the epidemiology", Inhalation Toxicology, 29:8, 341-341,001:10.1080/08958378.2017.1385114 To link to this article: http://d x.doi.org/10.1080/08958378.20 17.1385114 m Published online: 17 Oct 2017. ~' Submit your article to this journal 8' W!! Article views: 11 ~ ~ .... View related articles 8' (I) '-""" View Cross mark da ta 8' Full Terms & Conditions of access and use can be found at http://www.tandfonline.com/action/jou rnallnformation?journa1Code= iiht20 Download by: [NS LIJ HS Libraries] Date: 23 October 2017, At: 14:50 FILED: ERIE COUNTY CLERK 03/17/2023 08:48 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 284 RECEIVED NYSCEF: 03/17/2023 .. INHALATION TOXICOLOGY, 2017 VOL 29, NO. 8, 341 C\ ~ Taylor & Francis Taylor&Frand1Group https://dol.org/1 0.1080/08958378.2017.1385114 LETTER TO THE EDITOR Letter on: 11Cosmetic talc as a risk factor for pleural mesothelioma: a weight of evidence evaluation of the epidemiology" Sir, wide geographical variation, and Italy is no exception (Marinaccio et al., 2012). Piedmont incidence rates reflect Finley et al. (2017) reviewed the evidence regarding asbes- wide-spread occupational exposures to asbestos: from the tos-related cancers among talc miners and millers, finding Balangero mine, to different plants producing asbestos- no mesothelioma case in published relevant cohort studies. cement materials, asbestos textiles, asbestos-based brake and The Piedmont Registry of Malignant Mesotheliomas (RMM) clutch linings, railway carriages and other rolling stock is the regional operating center of the Italian National materials. A large part of the Italian asbestos industry was Mesothelioma Registry (Marinaccio et al., 2012). In 2007, located in Piedmont, with the exception of course of ship- after the mortality follow-up by Coggiola et al. (2003) had yards. Therefore, pleural mesothelioma incidence rates for been completed, we registered a case of pleural mesotheli- the Piedmont population are not the result of "background, oma (a man, aged 79) who reported to have been employed exposures. as a maintenance worker from 1947 to 1957 at the Talco and Grafite talc mill. Maintenance workers might have incurred exposure to asbestos for reasons different from Disclosure statement asbestos contamination of talc, which has been considered No fmancial interest or benefit has arisen from the present work. to be absent in the Val Germanasca talc mines (Rubino et al., 1976); however, it is worth mentioning that low-level exposure to airborne asbestos fibers was indeed reported by Funding Rubino et al. (1976). No funding has been received for the present work. RMM publishes and periodically up-dates mesothelioma incidence statistics for Piedmont. Age-standardized inci- dence rates in men increased from 2. 7 in 1990-1994 to 6.4 References per 100,000 person-years in 2010-2014 (standard: European Coggiola M, Bosio D, Pira E, et al. (2003). An update of a mortality population 27). Depending on how person-years were dis- study of talc miners and millers in Italy. Am J Ind Med 44:63-9. tributed by calendar period of observation in the Italian Finley BL, Benson SM, Marsh GM. (2017). Cosmetic talc as a risk fac- cohort of talc miners and millers, 2004 rates may have tor for pleural mesothelioma: a weight of evidence evaluation of the epidemiology. Inhal Toxicol 29:179-85. under- or overestimated the expected number of cases. Marinaccio A, Binazzi A, Marzio DD, et al. (2012). Pleural malignant Under- or overestimation may have also derived from using mesothelioma epidemic: incidence, modalities of asbestos exposure age-standardized instead of age-specific incidence rates, and occupations involved from the Italian National Register. lnt J depending on the age-distribution of person-time in the Cancer 130:2146-54. cohort. As the expected number of pleural cancer deaths in Rubino GF, Scansetti G, Piolatto G, Romano CA. (1976). Mortality study of talc miners and millers. J Occup Med 18:187-93. Coggiola et al. (2003) was 1.8, the 2.8 figure in Finley et al. (2017) table 1 is likely to be an overall overestimation. Dario Mirabelli These observations do not change the lack of excess Unit of Cancer Epidemiology, CPO Piemonte and mesothelioma deaths in the Val Germanasca cohort, but University of Turin, Turin. Italy suggest that the difference between observed and expected cases might be smaller than Finley et al:s estimate. I, lastly, e dario.mirabelli@cpo.it want to warn about the interpretation of the "expected, Received 14 July 2017; revised 3 August 2017; number of cases. Using regional reference rates may be in accepted 20 September 2017 general a reasonable epidemiological practice, but conditions such as pleural mesothelioma are well known to have very