Court File No.

12023/01 Ontario SUPERIOR COURT OF JUSTICE B E T W E E N: WILFRED ROBERT PEARSON Plaintiff - and INCO LIMITED, HER MAJESTY THE QUEEN IN RIGHT OF ONTARIO, THE CORPORATION OF THE CITY OF PORT COLBORNE, THE REGIONAL MUNICIPALITY OF NIAGARA, THE DISTRICT SCHOOL BOARD OF NIAGARA, and THE NIAGARA CATHOLIC DISTRICT SCHOOL BOARD Defendants Proceeding under the Class Proceedings Act, 1992

AFFIDAVIT OF DR. GEORGE C. BECKING I, George C. Becking, of the City of Kingston, MAKE OATH AND SAY: 1. I am a t xicologist and currently work with Phoenix OHC, Inc., in Kingston o

Ontario, as a specialist in human health risk assessment and with the World Health Organization as a Temporary Advisor on aspects of risk assessment. My education includes a doctoral degree in biochemstry as well as post-doctoral research in molecular biology. For 25 years I have been active in the field of human health risk assessment from exposure to environmental chemicals, with particular emphasis on the assessment of risks from metals. 2. I have previously served with Health Canada as Chief, Division of Environmental

and Occupational Toxicology, and with the World Health Organization as a Scientist responsible for accuracy of Environmental Health Criteria Documents. Over my career I ha ve participated in the setting of exposure guidelines on a national and international level, the development of

-2toxicity testing methods and the development of risk assessment methodologies. I have authored or co-authored about 60 articles published in peer-reviewed scientific journals as well as numerous other papers, book chapters and conference and symposium materials. A copy of my curriculum vitae is attached as Exhibit A. I have knowledge of the matters to which I depose in this affidavit, except where I have been advised of such matters, in which case I believe such information to be true. 3. I have reviewed the claim in this matter as well as certain of the materials served

by the plaintiff in support of the motion for class certification in this case, including the affidavit of Dr. Mark Richardson and the exhibits thereto. 4. At the request of Inco, I have prepared for the courts assistance a report that (i)

provides an overview of the toxicology and potential health effects of the chemicals identified in Dr. Richardsons affidavit and Exhibit B to his affidavit (entitled Summary of Health and Phytotoxic Effects) at the concentrations reported in the MOEs October 2001 Rodney Street report, and (ii) discusses what would be necessary to show that the presence of the listed chemicals actually caused adverse health outcomes in an individual Port Colborne resident. A copy of my report is attached as Exhibit B.

SWORN BEFORE ME at the City of Toronto on March 21, 2002. George C. Becking, Ph.D Commissioner for Taking Affidavits