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' I <br /> VERITOX <br /> REDMOND,WA • HILTON HEAD,SC • CAPE ELIZABETH, ME <br /> June 3,2015 <br /> Expert Report of Bruce J. Kelman,Ph.D., DABT, ATS, ERT <br /> I have been asked to provide an expert opinion as a toxicologist regarding human health <br /> effects from indoor exposure to bacteria, endotoxins,mold spores,and mycotoxins.I have <br /> extensive general knowledge in the field of toxicology and inhalation toxicology, and specific <br /> knowledge of the effects of mycotoxins from mold and endotoxins from bacteria in indoor <br /> environments. The following report outlines my relevant qualifications and opinions. <br /> I. Summary of Opinions <br /> Based on a review of the records provided to me in this matter and my general knowledge, <br /> training, and experience in the field of toxicology, and specific knowledge of the effects of <br /> bacteria and mold, as well as endotoxins from bacteria and mycotoxins from mold,I hold the <br /> following opinions: <br /> A. Mold and mold spores are ubiquitous and the construction and maintenance of a <br /> mold-free indoor environment is not possible. <br /> B. There are three principal, generally-recognized potential human health effects of <br /> mold: allergy, infection, and toxicity. <br /> C. The mere presence of any material, including mold, does not mean that exposure <br /> has occurred or will occur and does not allow conclusions as to the air <br /> concentration of material that would be associated with a given disease outcome. <br /> D. Only exposure to mold or mycotoxins at a sufficient dose can result in adverse <br /> health effects. <br /> E. The term"toxic mold"is without scientific meaning because mold is not <br /> inherently toxic. <br /> F. A temporal relationship alone cannot establish that exposure to mold spores at the <br /> Indian River County Fire Stations can cause illness. <br /> 18372 Redmond Way • Redmond,WA 98052 • Tel 425-556-5555 • Fax 425-556-5556 • www.veritox corn. <br /> 53 <br />