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flatlander_60048

05/06/24 11:35 PM

#29296 RE: DewDiligence #29274

This liability is potentially huge since every contamination case that goes to litigation will likely sue under this statute (private, state, federal etc). Joint and several liability allows litigants to pursue those involved that have deep pockets, even if the involvement is de-minimus. As a PFAS manufacturer, and a deep pocketed contributor, 3M could likely be named in a majority of the lawsuits. I suspect that we are very much on the leading edge of a wave of claims. With the recent EPA rules, Landfills and superfund sites will be required to start monitoring for PFAS constituents. Existing treatment systems may have to be redesigned to address PFAS. Landfills may detect the constituents in groundwater prompting off-site investigations, corrective action,. etc.. I don't want to attempt to put a dollar amount on any of this because these types of estimates have a tendency to undershoot as the liability will continue for decades.

I recently retired from a 35 year career, much of which included working on Superfund NPL sites. I know there is a tendency to not want to believe that a blue chip company can be significantly impaired by this type of impact. So don't shoot the messenger!

Regards
FL