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Over the past decade, wildfires have grown in size, duration and destructiveness due to the boom in biomass fuel production, changing climate conditions, rising temperatures, widespread drought and earlier snowmelt. Human error also has caused growth in the number of wildfires in recent years. From 2014 to 2017, the frequency of fires in the United States has been increasing at an estimated annualized rate of 5 percent burning more than 13.7 million acres, according to the National Interagency Fire Center.

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Asbestos, like any potential carcinogen (e.g., radiation or tobacco smoke), requires more than a nominal dose to result in disease. But to hear plaintiffs and their experts at trials throughout the country, there is no “safe” dose of asbestos.

However, it is not true that every exposure to asbestos contributes to asbestos disease, or that there is no “safe” dose of asbestos. As such, many courts nationwide are rejecting the “any exposure” theory or similar cumulative exposure approach in asbestos and other toxic tort litigation.

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