9. Dr. Rodricks claims that NCR knew or should have known that PCBs would be present in recycled paper made from NCR broke and used for food packaging, and NCR could have taken measures that would “prevent PCB contamination of food and food packaging, actions that would again have reduced or eliminated PCB contamination of the Kalamazoo.” Dr. Rodricks provides no evidence that recycling facilities on the [Fox]Kalamazoo River used any NCR broke in the manufacture of food packaging. FDA began surveillance of foods and food products in 1969 in response to concerns about PCBs; although the analytical technology to detect PCBs and differentiate them from DDT and other chlorinated pesticides was not refined until 1970. In 1972, after NCR had
