In Re: Methyl Tertiary Butyl Ether ("MTBE") Products Liability Litigation

Filing 3795

DECLARATION of Brent H. Allen in Support re: (235 in 1:04-cv-04973-SAS) MOTION for Settlement Defendant Coastal Chem, Inc.'s Notice of Motion and Motion for Good Faith Settlement.. Document filed by Coastal Chem, Inc.. (Attachments: #1 Exhibit 01, #2 Exhibit 02, #3 Exhibit 03, #4 Exhibit 04, #5 Exhibit 05, #6 Exhibit 06, #7 Exhibit 07, #8 Exhibit 08, #9 Exhibit 09, #10 Exhibit 10)Filed In Associated Cases: 1:00-cv-01898-SAS-DCF, 1:04-cv-04973-SAS(Allen, Brent)

Exhibit 7

40970676

City of Fresno v Chevron U.S.A. Inc., et al.
Report of Christine T. Wood, Ph.D.

Christine T. Wood, Ph.D.

Exponent Failure Analysis Associates, Inc.
149 Commonwealth Drive
Menlo Park, CA 94025

November 18, 2011

© Exponent, Inc.

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Nov 18 2011
3:26PM

stations.55 It is this existence of laws and regulations, and the enforcement thereof, that
increases compliance with warnings that are disseminated about the safe handling of gasoline.

Summary and Conclusions
In summary, I offer the following opinions with a reasonable degree of scientific certainty:
The safety messages contained in warnings and other information about gasoline releases
provided by defendants available to their customers are reasonable, adequate and sufficient to
communicate the proper precautions for storing and handling gasoline, whether it contains
MTBE or not.
The inclusion of additional or alternative information, such as that proposed by plaintiff, would
not change the safety practices among service station operators.
The inclusion of additional warnings would dilute the message of a simple warning not to
permit spills or leaks of gasoline, reducing its effectiveness.

55

Deposition of Gary Beacom, 08/10/2011, pp. 22, 24, 72; Deposition of Garabed Bedirian, 04/04/2011, pp. 41-42;
-67;
Deposition of Jatinder Paul Dhillon, 08/11/2011, pp. 26-27, 59, 62-64; Deposition of Babak Lakestani, 08/09/2011,
p. 36; Deposition of Bryan Leonard Moe, 08/17/2011, p. 43; Deposition of Joe Rebella, 03/15/2011, p. 40 (fire
department); Deposition of Judy Rogers, 03/08/2011, pp. 35-37; Deposition of Jeetander Sethi, 07/13/2011, pp. 26,
47-48, 90-91
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