Full opinion text
MEMORANDUM AND ORDER TRAGER, District Judge. Plaintiff Nikitas Amorgianos (“Mr. Amorgianos”) brought this action against the National Railroad Passenger Corporation (“Amtrak”) for personal injuries allegedly suffered as a result of workplace exposure to xylene. Plaintiff Donna Amorgianos (“Mrs. Amorgianos”), his wife, joined in the action, claiming loss of consortium and services. After a jury trial and a verdict rendered in favor of plaintiffs, Amtrak moved for a judgment as a matter of law or, in the alternative, for a new trial. The court denied defendant’s motion for judgment as a matter of law, but granted defendant’s motion for a new trial, finding that the jury’s verdict was against the weight of the evidence. Amtrak now moves to preclude plaintiffs’ experts from testifying at retrial on the ground that their testimony does not meet the standard for admissibility under Federal Rule of Evidence 702 set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc. and its progeny. Background Mr. Amorgianos is a forty-six year old man, who, until the time of the alleged accident giving rise to this action, had worked as a bridge painter since 1974. (Tr. 6/17/98, at 87-38.) Mr. Amorgianos, his wife, and his treating physician, Dr. Jacqueline Moline (“Dr. Moline”), all testified at trial that Mr. Amorgianos had been healthy prior to the incidents in question here. (Tr. 6/17/98, at 95, 129; Tr. 6/18/98, at 182.) (1) The Steinway Street Bridge Project On July 22, 1995, Mr. Amorgianos began working with a crew of painters employed by Romano Enterprises (“Romano”), which, along with two other painting companies, had been contracted to repaint the Steinway Street Bridge in Astoria, Queens (the “Steinway Street Bridge Project” or the “Project”). (Def.’s Letter Brief of 12/6/99, Ex. K; Tr. 6/24/98, at 40.) The Steinway Street Bridge is a street overpass for a rail line operated by defendant Amtrak. The bridge consists of three piers and two 120-foot spans; one span passes over Steinway Street, and the other passes over Twenty-Third Street. (Def.’s Letter Brief of 12/6/99, Ex. L.) The operation involved five steps: sandblasting off the old paint; applying a primer coat; applying a white, intermediate coat; applying a red, pigmented coat; and applying an anti-graffiti top coat to the portions of the bridge visible to pedestrians. (Tr. 6/17/98, at 50; Tr. 6/24/98, at 48-49.) Different steps in this process were performed on different sections of the bridge simultaneously. (Tr. 6/24/98, at 31-33.) For instance, while one group of workers was sandblasting part of one span, another group might have been applying primer to a section of the other span. Because the old paint was lead-based, it was necessary to enclose whichever particular section was being sandblasted in order to protect pedestrians from exposure to lead paint dust blown off the bridge. (Tr. 6/24/98, at 50.) For this purpose, a box-shaped containment consisting of tarpaulins which were fastened together was erected around the affected section of the bridge and its supporting undercarriage during the sandblasting operation. (Tr. 6/17/98, at 42, 44.) At trial, Mr. Amorgia-nos testified that the containment was approximately 75 to 100 feet long, (id. at 41.); Ralph P. Romano, a co-owner of Romano Enterprises, testified that it was about 100 feet long, (Tr. 6/24/98, at 47). Mr. Romano further testified that the containment was about 15 to 18 feet high and 50 feet wide, (Tr. 6/24/28, at 47). The containment was fitted with a vacuum hose on one end to carry lead paint dust out of the interior space and into a dust collector. (Tr. 6/17/98, at 42.) There were two louvers on the wall of the containment opposite from the dust collector intake. The louvers could be opened or closed as needed to introduce fresh air into the containment and to facilitate the flow of air through it. (Id. at 44; Tr. 6/24/98, at 50-51.) The same type of containment was used during the spray-painting phases of the operation in order to keep paint overspray from falling on pedestrians and the surrounding area. (Tr. 6/24/98, at 50.) Romano time records indicate that Mr. Amorgianos began working on the Steinway Street Bridge Project on July 22, 1995, and continued on the job until his alleged accident on August 28, 1995. (Def.’s Letter Brief of 12/6/99, Ex. K.) (2) Plaintiffs’ Claims The gravamen of plaintiffs’ complaint is that Mr. Amorgianos was not provided with the appropriate personal protective gear, the containment was not properly ventilated, and, as a result, he was exposed to dangerous concentrations of paint fumes while spray-painting inside the containment. Exposure to organic solvent vapors in the paint fumes, particularly xylene vapor, he contends, caused him to develop permanently disabling (1) central nervous system (“CNS”) dysfunctions, such as memory loss, cognitive deficits, and changes in affect, and (2) peripheral poly-neuropathy (“PN”), a neurological condition involving the loss of sensation and motor control in the extremities. Specifically, plaintiffs contend that proper industrial hygienic practice is to provide a spray-painter who is working inside an enclosed space with a respirator containing a filter specially designed for organic solvent vapors. According to plaintiffs, these filters must be changed on a daily basis, or they become ineffective. Mr. Amorgianos alleges that Romano failed to provide him with an adequate supply of fresh organic vapor filters. In addition, plaintiffs contend that proper industrial hygienic practice would have been to turn the dust collector on and open the fresh air vents during spray-painting; Mr. Amorgianos alleges that this was not done on the Steinway Street Bridge Project. Plaintiffs also assert that a fan should have been placed inside the containment to increase air flow further. Plaintiffs contend that the failure to provide adequate air flow through the containment allowed dangerous levels of organic solvent vapors to accumulate within the containment, exacerbating the danger posed to Mr. Amorgianos by defendant’s alleged failure to provide him with the appropriate filters for his respirator. On the afternoon of August 28,1995, Mr. Amorgianos became acutely ill allegedly due to his exposure to the paint fumes, left work, and has allegedly suffered disabling CNS deficits and PN since that date, with no improvement over time. As detailed below, the various expert and non-expert factual issues raised by plaintiffs’ claims were contested at trial. (3) The Evidence at Trial Plaintiffs’ action came for jury trial before the Honorable Edward R. Korman of this Court (the “trial judge”) in June, 1998. A. Personal Protective Gear Provided to Mr. Amorgianos 1. Plaintiffs’ Evidence When Mr. Amorgianos started on the Project, he was provided with a half-face respirator mask. (Tr. 6/17/98, at 58-60.) The respirator could be fitted with a lead dust filter and/or with a filter for organic vapors. (Id. at 59-60, 62.) The lead dust filter was to be used during sandblasting, while organic vapor filters were to be used during spray-painting. (Id.) Mr. Amorgi-anos testified that at certain times during his work on the Project, he sandblasted, and at other times, he spray-painted; both activities were performed inside the containment. (Id. at 59-61.) "While sandblasting, Mr. Amorgianos was also provided with a cloth hood, which ■ covered his head and uniform. (Id. at 45.) The hood was connected to a hose that brought in fresh air from outside the containment. (Id.) Mr. Amorgianos did not, however, wear the respirator underneath the air-supplied hood during sandblasting. (Id. at 45.) Mr. Amorgianos complained that the dust collector used during sandblasting did not have enough capacity to clear adequately the air within the containment. (Id. at 43-45.) With regard to spray-painting, Mr. Amorgianos stated that there were occasions during his first three or four weeks on the Project (i.e., from July 22, 1995 to August 11 or August 18, 1995) that he performed spray-painting work. (Id. at 59.) Mr. Amorgianos was provided with a single organic vapor filter for his respirator at that time, but was not given a replacement, and was forced to use that same organic vapor filter for “a couple of weeks.” (Id. at 60.) Later in the operation, he returned to spray-painting, but he was told no organic vapor filters were available, so he used only a lead dust filter for at least the last two weeks he was on the job (i.e., August 15, 1995 to August 28, 1995). (Id. at 61-62.) Mr. Amorgianos further testified that the dust collector was not turned on during spray-painting, the fresh air louvers were kept closed, and there was no fan inside the containment. (Id. at 50-53, 58.) During Mr. Amorgianos’s direct examination, plaintiffs introduced what they alleged to be the actual respirator Mr. Amorgianos was using when he became ill on August 28, 1995. (Id. at 78, 82.) Mr. Amorgianos testified that he had been using that very respirator for the preceding two or three weeks, including during spray-painting. (Id. at 83.) The respirator, as introduced, contained only a lead dust filter. (Id. at 78, 83.) Mr. Amorgia-nos stated that he had used that particular filter for the last three days he worked. (Id. at 76.) As later noted by the trial judge, the respirator and filter were in clean, “rather pristine” condition. (Tr. 9/29/98, at 38; see also id. at 36-37 (noting that there was “not a speck of paint on the mask”), 42-45.) Plaintiffs’ expert industrial hygienist, Jack Caravanos (“Caravanos”), who testified after Mr. Amorgianos, stated on cross-examination that after one week or even one day of use, he would expect to see paint particles deposited on the lead dust filter, which is pink. (Tr. 6/18/98, at 79-80.) When shown the respirator Mr. Amorgianos allegedly used for the last two weeks of the job, Caravanos acknowledged that there was no identifiable paint residue on its exterior or on the filter. (Id. at 82, 89-91.) On redirect, plaintiffs’ counsel asked Ca-ravanos to assume that Mr. Amorgianos had placed a T-shirt over the front of his respirator while painting, (id. at 99), though Mr. Amorgianos had given no such testimony. Plaintiffs’ counsel asked whether under those circumstances Cara-vanos would expect to see paint materials on the respirator or filter; Caravanos answered “no.” (Id. at 99-100.) Caravanos also opined that the paints Mr. Amorgia-nos used — including those labeled “pigmented” epoxy and the third coat, which Caravanos previously testified “was a very unique color, sort of the color of maroon, so I remember it quite well,” (id. at 9)— might actually be colorless and that, as a result, it would only be possible to detect paint on the respirator through chemical analysis, (id. at 91, 99-100, 117-118.) Ca-ravanos performed no chemical analysis on the respirator or filter. (Id. at 89.) Plaintiffs subsequently called a friend of Mr. Amorgianos and a fellow painter on the Project, Nikos Kpitikos (“Kpitikos”). (See Tr. 6/23/98, at 3-4.) Kpitikos testified that the “company used to send the [organic vapor] filters [to the site] but somebody used to take it and they didn’t give it to us.” (Id. at 12; see also id. at 13 (“The company used to send it but nobody gave it to us. They were disappearing.”).) As a result, while painting, he and the other workers would put a piece of cloth or a blouse over the front of the respirator mask. (Id. at 13-14.) Kpitikos also stated that, although it was available, the workers would not use air-supplied hoods during painting because they were bulky and made maneuvering around the bridge’s undercarriage difficult. (Id. at 10-12.) In an expert report prepared after the first trial, plaintiffs’ new putative expert on neurology and toxicology, Dr. Jonathan S. Rutchik (“Dr. Rutchik”), stated that Mr. Amorgianos had described his protective gear as follows: gloves, boots, a Tyvek suit, a half-face mask respirator with lead dust filters, no goggles, and no hood or outside air hose. (See Def.’s Letter Brief of 12/6/99, Ex. D, at 3 (Dr. Rutchik’s Expert Report).) Dr. Rutchik’s report makes no mention of a practice of covering the front of the respirator with a T-shirt. (See id.) 2. Defense Evidence Defendants called Robert Faulkner (“Faulkner”), who worked as the foreman on the Project during the week beginning August 23, 1995. (Tr. 6/23/98, at 199-200, 204-205.) Faulkner testified that during spray-painting, the painters wore air-supplied Tyvek spray hoods, respirators and organic vapor filters. (Id. at 201-02.) Faulkner stated that at no time that week were organic vapor filters unavailable and that Mr. Amorgianos never complained that he did not have one. (Id. at 202.) On Mr. Amorgianos’s last day of work, Faulkner observed him coming out of the containment wearing a Tyvek suit and a respirator. (Id. at 204.) Defendants also called John Strika (“Strika”), the chairman of the greater New York bridge painters’ union. (Tr. 6/24/98, at 8-9.) Strika testified that he worked as a job steward on the Project throughout July and August 1995 (with the exception of the week of August 23-29, when he was on vacation), and that his son worked on the Project as a painter at the same time. (Id. at 9-10, 12-13, 14-15, 19-20.) Strika testified that there was a ready supply of organic vapor filters on hand at all times and that he had received no complaints from the painters that they were not available. (Id. at 11-12.) Strika did not see any painters using respirators with T-shirts wrapped around them. (Id. at 13.) However, according to Strika, the painters did not use respirators at all during painting, but instead used soft hoods with pressurized air supplies. (Id. at 21-23.) The hood was necessary to keep the paint vapors from burning the painters’ eyes and to keep paint out of the painters’ faces. (Id. at 27, 34-35 (explaining that the front of the hood had multiple layers of a clear cellophane-like material, which could be peeled off one by one as each became covered with paint).) Ralph P. Romano, one of the owners of Romano Enterprises, testified that there were always organic vapor filters available on site. (Tr. 6/24/98, at 60.) Mr. Romano also testified that he visited the site on a number of occasions and would sometimes go into the containment. (Id. at 56.) On those occasions, he would wear a Tyvek suit with an air-supplied hood, but no respirator. (Id.) On such occasions during July and August 1995, he observed the painters wearing Tyvek suits and hoods. (Id. at 57.) B. Standard Industrial Hygienic Practice On the issue of what standard industrial hygiene required in the way of personal protective gear and ventilation on the Project plaintiffs offered the testimony of their certified industrial hygienist, Jack Caravanos. Defendant called a certified industrial hygienist of its own, Frederick Toca (“Toca”). The two witnesses were in agreement that a lead dust filter (with or without a T-shirt wrapped over it) is completely ineffective at filtering organic solvents and that proper industrial hygienic practice is to provide painters working in an enclosed space with a ready supply of organic vapor filters. (See Tr. 6/18/98, at 30-31, 38 (Ca-ravanos); Tr. 6/23/98, at 146-47, 159-60, 166 (Toca).) Neither Caravanos nor Toca testified as to whether use of an air-supplied hood without a respirator and organic vapor filter would be effective protection against organic solvent vapors. On the issue of proper ventilation, Cara-vanos testified the dust collector should have been turned on, a fan should have been inside the containment, and the fresh air louvers should have been opened in order to prevent a concentration of organic solvent from accumulating inside the containment during the spray-painting operation. (Tr. 6/18/98, at 23, 27-28.) For his part, Toca was unwilling to opine on whether such ventilation was necessary without having seen how much ventilation was already available through the seams in the containment and its entryway. (Tr. 6/23/98, at 166-67, 171-73.) Toca, however, said that he would defer to the opinion of the industrial hygienist who had been contracted to inspect the site, Robert Leighton (“Leighton”) of Leighton Associates, Inc. (Id. at 167-68.) Leighton separately testified that he believed that the dust collector should have been on and the air louvers opened during both sandblasting and spray-painting. (Tr. 6/22/98, at 117, 124.) Therefore, there was no serious dispute at trial that the safety measures (or lack thereof) alleged by Mr. Amorgianos — viz., use of a respirator fitted only with a lead dust filter and the absence of ventilation inside the containment would represent a departure from proper industrial hygienic practice. C. Mr. Amorgianos’s Alleged Illness 1. Direct Examination of Mr. Amor-gianos On direct examination, Mr. Amorgianos testified as follows regarding his alleged illness. On August 28, 1995, Mr. Amorgianos started work at 7:00 a.m., stopped work at 2:30 p.m., and took two 10 minutes breaks in between. (Tr. 6/17/98, at 87.) Throughout the day, he spray-painted inside the containment, wearing only a respirator with a lead dust filter. (Id. at 87, 90.) Toward the end of the day, he began to feel dizzy. (Id. at 89.) His eyes started to close, and he felt exhausted. (Id.) When he finished working, he could not open his eyes and had to call his wife to pick him up from work. (Id. at 90.) He went home with a fever of 103 degrees. (Id.) His whole body was swollen and itchy, and his joints would not move. (Id. at 90-91.) The next morning, August 29th, he felt worse and did not go to work. (Id. at 91.) The following day, August 30th, he showed the same symptoms and was now sweaty and had headaches. (Id.) At that point, Mr. Amorgianos visited a neighborhood doctor, who prescribed pills for his itching and swelling. (Id. at 92.) That doctor referred to him to one Dr. Vlattas, whom he visited a week later, just after Labor Day, 1995. (Id.) At that point, his condition was not any better, he could not move from bed, and Dr. Vlattas recommended that he see an internist. (Id. at 92-93.) Sometime in September, 1995, on Dr. Vlattas’s recommendation, Mr. Amorgia-nos visited Dr. Moline, a board certified internist and the director of the occupational medicine program at Mount Sinai Hospital in Manhattan. {Id. at 93.) Dr. Moline ordered an MRI of his brain and blood tests. {Id. at 94.) Mr. Amorgianos continued to see Dr. Moline every four to six weeks from then until the trial in June, 1998. {Id.) Mr. Amorgianos testified that during that approximately three-year period his condition did not change, but in fact became worse. {Id.) He allegedly has no feeling in his hands, he drops things, his knees buckle beneath him, and he can no longer walk as well as he could before the exposure. {Id. at 94-95.) Every day, he gets worse. {Id.) He has no reflexes on the left side of his body, and his whole body is numb and tingly. {Id. at 95.) He can no longer do outdoor or athletic activities. {Id.) A typical day for him as of the time of trial was to stay at home and depend on his wife for everything. {Id.) His wife must help him dress, and sometimes, he is unable to get off of the toilet by himself because his body becomes numb. {Id. at 95-96.) He is depressed and can no longer have sex or work. {Id. at 96.) 2. Cross Examination of Mr. Amor-gianos On cross-examination, Mr. Amorgianos testified that there had never been a period from August, 1995 to the trial during which he felt better. {Id. at 108.) During that time, he was able to leave the house to have dinner with his wife only “a couple of times.” {Id.) However, Mr. Amorgianos admitted that, notwithstanding his alleged condition, he had in fact vacationed in Greece two or three times during that period. {Id. at 109.) In addition, he admitted that he can and does drive a car and that he had traveled to Ohio in October 1996. {Id. at 109-110.) While in Ohio, Mr. Amorgianos was involved in a car accident. {Id. at 110.) During the accident, he hit his head and developed a headache, so he took a taxi to the emergency room at St. Joseph Health Center in Warren, Ohio (“St. Joseph’s”). {Id. at 110, 124, 125.) The emergency room notes, which were admitted into evidence, read as the follows: “The patient denies any weakness or numbness. He said his headache has improved significantly after he took ... aspirin. He denies any weakness or numbness.” {Id. at 113— 14 (St. Joseph’s ER dictation, 10/20/96).) In addition, as was revealed during cross-examination of Dr. Moline, St. Joseph’s records indicate that Mr. Amorgianos was given a complete neurological workup, including a cervical spine X-ray and CT scan, all with normal results. (Tr. 6/18/98, at 143.) The records further report: (1) “Grasp — both hands normal;” (2) “no sensory or motor deficit;” (3) normal reflexes in both the upper and lower extremities; (4) that Mr. Amorgianos was alert and oriented as to person, place and time; (5) a nurse’s note reading “bilateral, equal, strong hand grasp, steady gait;” (6) “motor strength five over five;” (7) a normal sensory exam; and (8) “healthy” in a blank for past medical history. {Id. at 143-48.) Nonetheless, Mr. Amorgianos testified that there have been no times since his accident that he has been able to walk normally. (Tr. 6/17/98, at 116.) Two or three blocks is the maximum that he can walk. {Id.) After that, he gets tired, and his knees buckle beneath him. {Id.) 3. The Surveillance Video At that point in Mr. Amorgianos’s testimony, the defense revealed, outside the presence of the jury, the existence of a video surveillance tape taken of Mr. Amor-gianos in Queens, New York on June 3, 1998. (Id. at 117-122, 141.) The tape, which was admitted into evidence and later played for the jury, shows Mr. Amorgianos driving, walking without a cane or any other type of assistance for many blocks, entering and leaving a coffee shop and a bank, all over the course of the morning and afternoon. (See Pis.’ Ex. 12, received 6/22/98.) As described by the trial judge, the tape showed Mr. Amorgianos walking “much more than a quarter of a mile without any difficulty.” (Tr. 9/29/98, at 69; see also id. at 34-35). 4. Mrs. Amorgianos’s Testimony Notwithstanding the surveillance video, Mrs. Amorgianos subsequently testified that her husband’s condition has only become worse since August, 1995. (Tr. 6/17/98, at 132.) According to her, he cannot walk up two steps, or he will fall down. (Id.) He cannot hold a bottle of ketchup or a cup of coffee. (Id. at 132, 139-40.) He has numbness and tingling all the time and sometimes cannot get off the toilet by himself. (Id.) He cannot sleep, he sweats all night, and he cannot have sex. (Id. at 132-33.) He has not worked since August, 1995. (Id. at 134.) He cannot dress or bathe himself. (Id. at 135.) On a typical day, he gets up, has breakfast, sometimes tries to go for a walk, but gets exhausted and spends the rest of the day on the couch. (Id. at 136.) In addition, Mrs. Amorgianos testified that her husband’s emotional and cognitive functions have been impaired. According to her, Mr. Amorgianos is depressed, non-communicative and emotionless. (Id. at 134-35.) His memory is very short-term, and he cannot remember anything. (Id. at 140.) 5. Dr. Moline’s Testimony Dr. Moline was also called to testify regarding Mr. Amorgianos’s medical condition. Dr. Moline stated that she had seen Mr. Amorgianos 16 or 17 times and, during that period, his symptoms have essentially remained constant. (Tr. 6/18/98, at 125.) According to Dr. Moline, he is profoundly weak, the range of motion in his joints is significantly limited, he has difficulty moving his knees, and he cannot lift his left arm. (Id. at 126,168.) Dr. Moline related at length what Mr. Amorgianos had told her about his condition. He reported to her that he has trouble dressing. (Id. at 163.) He has difficulty gripping a coffee cup, his arms are weak, his knees buckle when he walks, and his reflexes are gone so that he cannot break his fall. (Id.) He cannot walk for a quarter of a mile, but rather only five or six blocks. (Id. at 134, 162.) He feels constant numbness and tingling. (Id. at 127.) Dr. Moline had a battery of tests performed on Mr. Amorgianos, including elec-tromyography (“EMG”), nerve conduction velocity studies (“NCVS”), reflex tests and grip strength tests. The results were worse than normal, though asymmetrical in their distribution across his body: his grip strength was about jé of what it should be in his right hand, but only to % of what it should be in his left hand. (Id. at 128-29.) Mr. Amorgianos’s “[ljeft hand was always significantly worse than [his] right.” (Id. at 129.) Based on these results, Dr. Moline opined that Mr. Amor-gianos was suffering from a peripheral neuropathy, permanent in nature. (Id. at 131-32.) In addition, based on the elimination of known causes of peripheral neu-ropathy, such as diabetes, Dr. Moline opined that Mr. Amorgianos’s peripheral neuropathy was caused by his workplace exposure to organic solvents. (Id.) On cross-examination, Dr. Moline was extensively questioned about the Ohio medical records and stated that they had no effect on her opinion that Mr. Amorgia-nos suffers from peripheral neuropathy. (Id. at 143-49, 180.) In addition, notwithstanding Mr. Amorgianos’s testimony that there has never been a time since the accident that he felt better, Dr. Moline, who had been advised by plaintiffs’ counsel of the surveillance video showing Mr. Amorgianos walking throughout the course of a day, testified that sometimes Mr. Amorgianos has good days on which he is able to walk farther, and sometimes he has bad days. (Id. at 161, 164.) Finally, when questioned whether the EMG and NCVS she had performed on Mr. Amorgianos supported her diagnosis of peripheral neu-ropathy, Dr. Moline acknowledged that she was not personally qualified to interpret EMGs or NCVS and testified that she was relying on an interpretation of the results of those tests by a Mount Sinai physiatrist, Dr. Nahid Nainzadeh, and a Mount Sinai neurologist, Dr. Carl Bazil. (Id. at 151-155.) 6. Defense Medical Witnesses a. Dr. Rubin On the issue of Mr. Amorgianos’s diagnosis, the defense called Dr. Michael Rubin, a neurologist. (Tr. 6/22/98, at 3.) Dr. Rubin is the director of the EMG lab and neuromuscular service at New York Hospital-Cornell Medical Center and an associate professor at Cornell University Medical College. (Id. at 6.) Dr. Rubin was retained to examine Mr. Amorgianos by an independent medical examination (“IME”) provider. (Id. at 8.) Dr. Rubin examined Mr. Amorgianos on April 2, 1996. (Id. at 8.) Mr. Amorgianos reported that following exposure to epoxy paint in an enclosed space on August 28, 1995, he had suffered numbness and tingling over his whole body, though more so on the left side, as well as pain in his bones. (Id. at 9.) Mr. Amorgianos also reported that following the accident, his knees would begin to give out, and he found it difficult to walk. (Id.) Mr. Amor-gianos stated that he had not had any problems prior to the August, 1995 exposure. (Id.) Dr. Rubin conducted a physical exam and found Mr. Amorgianos’s responses were “entirely normal except for sensation testing.” (Id. at 10.) Dr. Rubin testified that these sensation tests are subjective, meaning that the physician simply records whatever the patient tells him or her. (Id.) Mr. Amorgianos reported decreased sensitivity to pin prick and vibration over his left arm and leg, and over his chest and abdomen. (Id.) His mental status, strength, reflexes, walking, balance and coordination were normal. (Id. at 10, 50.) Dr. Rubin also performed an EMG and NCVS. (Id. at 10-11.) The results did not evidence peripheral neuropathy, though a single abnormal result in his left arm suggested a pinched nerve in the neck. (Id. at 11-13.) Dr. Rubin recommended that Mr. Amorgianos return to work. (Id. at 13.) b. Dr. Budabin The defense also called Dr. Murray Bu-dabin. Dr. Budabin is board-certified neurologist and an associate clinical professor of neurology at Mount Sinai Hospital in Manhattan. (Tr. 6/23/98, at 56.) Dr. Bu-dabin was retained by the defense to examine Mr. Amorgianos and did so on October 7, 1997. (Id. at 58.) Mr. Amorgianos complained of weakness, numbness, tingling and joint pain. (Id. at 61.) Upon neurological examination, Mr. Amorgianos showed abnormal signs on tests that the examinee can voluntarily control, such as gait or arm strength, but on objective testing, his peripheral nerve responses were normal. (Id. at 68.) Review of an EMG and NCVS that had been performed by a Dr. Kyriakides for Dr. Vlattas, showed an abnormal results in Mr. Amorgianos’s left calf muscle and in his left and right deltoids, but his NCVS was normal. (Id. at 90, 92-98, 99). Dr. Budabin testified that these results provided no evidence of peripheral neuropathy; the abnormal result for the deltoids and left calf muscle was indicative of a possible cervical radiculopa-thy. (Id. at 98.) According to Dr. Buda-bin, cervical radiculopathy most commonly results from a particular nerve in the cervical spine being compressed at its root by a herniated disc or being traumatically injured; cervical radiculopathy is not caused by exposure to toxic substances. (Id. at 101-102.) Dr. Budabin opined that based on Mr. Amorgianos’s history, his physical examination, the EMG and NCVS, there was no evidence of peripheral neuropathy. (Id. at 102.) 7. Health Condition of the Other Workers on the Project Although there were six to eight workers on the Project, (Tr. 6/17/98, at 88-85), no evidence was presented that any of the other workers suffered the type of permanent illnesses Mr. Amorgianos alleges. D. Causation Testimony 1. Caravanos Plaintiffs presented Caravanos, a certified industrial hygienist, on, inter alia, the issue of causation. (Tr. 6/18/98, at 3.) Ca-ravanos holds a B.S. in Environmental Health Science from the City University of New York, an M.S. in Environmental Health from Brooklyn Polytechnic Institute, and a Doctorate in Public Health from Columbia University. (Id. at 2.) He is the chairman of the Hunter College industrial hygiene program and also serves as an adjunct assistant professor at Robert Wood Johnson Medical School of the University of Health and Dentistry of New Jersey. (Id. at 4, 6.) Caravanos testified that because the enclosure in which Mr. Amorgianos worked was airtight and the fresh air louvers were kept closed during spray-painting, paint fumes accumulated within the enclosure. (Id. at 12.) These fumes consisted of vapor from the organic solvents of which the paint products used on the Project were partly composed. (Id. at 25.) Caravanos opined that the concentration of these vapors within the containment had reached dangerous, life-threatening levels. (Id. at 23-24.) Specifically, Caravanos opined that, based on his calculations of the amounts of paint used, the volume of the containment, and the amounts of organic solvents within the paint products, the concentration of a particular organic solvent, xylene, was in the “thousands” of parts per million (“ppm”). (Id. at 40-41.) Carava-nos further testified that the Occupational and Safety Administration (“OSHA”) has promulgated a personal exposure limit (“PEL”) for xylene of 100 ppm. (Id. at 41.) Caravanos opined that Mr. Amorgi- anos’s exposure to a concentration of xylene in excess of the OSHA PEL, without the protection of a respirator fitted with an organic vapor filter, was the likely cause of Mr. Amorgianos’s alleged illness. (Id. at 52-53.) On cross-examination, Caravanos admitted that he did not have a medical degree. (Id. at 59.) His opinion that exposure to xylene at levels he estimated caused Mr. Amorgianos’s particular set of symptoms was based on a literature search on medical databases. (Id. at 60.) Specifically, he searched MEDLINE and TOXLINE for the key words “xylene poisoning in painters” and found hundreds of references. (Id. at 110-11.) So, he “just printed the first 50.” (Id. at 111.) When asked whether he read the referenced articles themselves, Caravanos stated that he had “read some of the abstracts.” (Id. at 111.) At that point, the trial judge ordered that his testimony on causation be stricken as incompetent in light of his failure to read any of the articles and the fact that he is not an epidemiologist. (Id. at 112-16.) 2. Dr. Moline Dr. Moline testified briefly that she believed to a reasonable degree of medical certainty that Mr. Amorgianos’s exposure to organic solvents on the Project caused Ms peripheral neuropathy, based on the chemicals to which he was exposed, the timing of the onset of his illness, his manifestation of symptoms described in the medical literature on organic solvents, and her elimination of known causes of PN, such as diabetes. (Id. at 132-33.) 3. Dr. Budabin Dr. Budabin was not questioned at length on the issue of causation, but he testified that exposure to toxic substances would not cause a neuropathy that was asymmetrical in nature, except if one were to place one’s hand into a toxic substance. (Tr. 6/23/98, at 69.) Dr. Budabin testified that since other types of chemical exposure (such as inhalation) have a systemic effect, any resulting neuropathy would be equal in both sides of the body. (Id.) Such an effect would stand in contrast to Mr. Amorgianos’s alleged symptoms, which were allegedly much worse on the left side of his body than the right. (Id.) (4) The Verdict On June 26, 1998, the jury returned a verdict for plaintiffs in the amount of $2.3 million after adjusting for its finding that Mr. Amorgianos was comparatively 30% at fault. (5) Post-Trial Proceedings On August 7, 1998, defendant moved for judgment as a matter of law or, in the alternative, for a new trial. On September 29, 1998, the trial judge denied defendant’s motion for judgment as a matter of law, but granted its motion for a new trial, finding that the verdict was “fundamentally against the overwhelming weight of the evidence” and represented a “miscarriage of justice.” (Tr. 9/29/98, at 67.) The trial judge based his decision on a number of factors, including: (1) the video surveillance tape, which showed Mr. Amorgianos walking “much more than a quarter of a mile without any difficulty,” (id. at 69; see also id. at 34-35); (2) the Ohio medical records related to Mr. Amorgianos’s car accident, which showed a normal neurological exam and in which he reported none of the symptoms claimed in the present action, (see id. at 35, 68-69, 71-72); (3) defense neurologists had testified that the effects of toxically-induced peripheral neuropathy typically present in an symmetrical pattern, but plaintiff’s alleged peripheral neuropathic illness was asymmetrical, (see id. at 36, 64, 68); (4) the absence of any paint residue on the respirator plaintiff allegedly used on the Steinway Street Bridge Project, and plaintiffs failure to produce any plausible explanation for its “rather pristine” condition, (see id. at 36-38, 42-45); and (5) the deficiencies in plaintiffs’ medical evidence, including the fact that Caravanos had offered an opinion on general causation based only on a review of article abstracts and not the articles themselves, (see id. at 38, 51); and doubts as to the credibility of Dr. Moline’s trial testimony, (see id. at 54, 72-73). The trial judge expressly noted that his decision was not based on any one of these factors considered in isolation but rather on the cumulative effect of all of them taken together. (See id. at 45, 69-70.) At plaintiffs’ request, this case was reassigned to the undersigned judge for retrial. Subsequently, plaintiffs retained a new putative expert on neurotoxicology, Dr. Jonathan S. Rutchik, and defendant retained a new toxicology expert of its own, Dr. Jack W. Snyder. After the completion of additional expert discovery, defendant moved to preclude plaintiffs’ expert witnesses on the ground that their opinions were not sufficiently reliable under the standards set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc. and its progeny. Discussion (1) Under New York law, when the determination of whether an illness or injury was caused by some event or conduct is “presumed not to be within common knowledge and experience,” a plaintiff must produce expert opinion evidence “based on suitable hypotheses” in order to support a finding of causation. Meiselman v. Crown Heights Hosp., 285 N.Y. 389, 396, 34 N.E.2d 367, 370 (1941); see Fane v. Zimmer, Inc., 927 F.2d 124, 131 (2d Cir.1991). As a threshold matter, it must be noted that this is not a case in which the burden-shifting analysis announced in Martin v. Herzog, 228 N.Y. 164, 126 N.E. 814 (1920), applies. In Martin v. Herzog, Judge Cardozo held that there is prima facie evidence of a causal link between an offending party’s negligence and a victim’s injury where the offending party violates an ordinance enacted to protect human safety and the victim suffers the very type of injury the ordinance was designed to protect against. See Martin v. Herzog, 228 N.Y. at 170, 126 N.E. at 816; see also Valencia v. Lee, 123 F.Supp.2d 666, 685-86 (E.D.N.Y.2000) (applying New York law) (shifting burden on causation where infant plaintiff, who had blood lead levels above limit established by federal and municipal health agencies, developed learning disabilities). Here, it will be assumed for the purpose of deciding this motion that Mr. Amorgianos was exposed to xylene in concentrations in excess of the 100 ppm PEL or the 150 ppm short-term exposure limit (“STEL”) promulgated by OSHA. Mr. Amorgianos’s alleged illness, however, is not of the type that the OSHA PEL and STEL for xylene were promulgated to protect against. In the release notes accompanying its promulgation of the xylene PEL and STEL, OSHA stated that it adopted the xylene PEL and STEL to protect workers against three specific adverse health effects: (1) narcosis; (2) eye irritation; and (3) adverse serologic effects. See Air Contaminants, 54 Fed.Reg. 2332, 2477 (1989) (final rule amending 29 C.F.R. § 1910.1000). The 1989 release notes — which post-date most of the research cited by plaintiffs’ experts, see infra Appendix tbls. 1-3 — do not recite chronic CNS or PNS effects as a justification for the adopted PEL or STEL. See id. Thus, even if one assumes that Caravanos’s estimate of the concentration of xylene within the containment is correct, plaintiffs are not entitled to shift the burden of proof on causation to defendant under the rule of Martin v. Herzog based on the alleged violation of the OSHA exposure limits. Accordingly, this case presents five distinct issues on which plaintiffs must produce admissible expert opinion evidence: (1) What does standard industrial hygienic practice require in the way of personal protective gear and ventilation for the type of spray-painting operation conducted during the Steinway Street Bridge Project?; (2) Is plaintiff ill, and, if so, what is his diagnosis?; (3) To what dose of xylene or other organic solvents was plaintiff exposed while on the Project, and for what duration?; (4) Can exposure to xylene (or the other organic solvents contained in the paint products with which plaintiff worked) in the amount and for the duration experienced by plaintiff cause an individual to develop the particular complex of CNS and PNS symptoms that plaintiff allegedly suffers?; and (5)Was plaintiffs exposure to xylene (and other organic solvents) the specific cause of his alleged development of these CNS and PNS symptoms? The issue presented by question (4) is commonly referred to as that of “general causation,” and that presented by question (5) as “specific causation.” See Mancuso v. Consolidated Edison Co. of N.Y., 56 F.Supp.2d 391, 394-95 (S.D.N.Y.1999), aff'd in relevant part, 216 F.3d 1072, 2000 WL 730417 (2d Cir.2000) (Table). Plaintiffs have proffered Dr. Moline, Ca-ravanos, and a new putative expert on toxicology and neurology, Dr. Jonathan S. Rutchik (“Dr. Rutchik”), to testify on these questions. Defendant has moved to exclude the testimony of these witnesses on questions (3) and (4), on the ground that their opinions as to the dose and duration of Mr. Amorigianos’s exposure to xylene and on general causation are not sufficiently reliable to meet the standards for admissibility under Federal Rule of Evidence 702 set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579, 113 S.Ct. 2786, 125 L.Ed.2d 469 (1993), and its progeny. Effective December 1, 2000, Rule 702 provides: If scientific, technical, or other specialized knowledge will assist the trier of fact to understand the evidence or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience, training, or education, may testify thereto in the form of an opinion or otherwise, if (1) the testimony is based upon sufficient facts or data, (2) the testimony is the product of reliable principles and methods, and (3) the witness has applied the principles and methods reliably to the facts of the case. Fed.R.Evid. 702. The proponent of expert evidence under Rule 702 must establish its admissibility by a preponderance of the evidence. See id. adv. committee note (2000 Amendments) (citing Bourjaily v. United States, 483 U.S. 171, 107 S.Ct. 2775, 97 L.Ed.2d 144 (1987)); Daubert, 509 U.S. at 592 n. 10, 113 S.Ct. at 2796 n. 10. A. Daubert In its landmark decision in Daubert, the Supreme Court established a two-prong test for admissibility of expert scientific testimony: the testimony must (1) relate to “scientific knowledge” and (2) “assist the trier of fact to understand or determine a fact in issue.” 509 U.S. at 592, 113 S.Ct. at 2796. The Court described the first requirement as one of “evidentiary reliability,” and the second as one of “fit.” Id. at 589-92, 113 S.Ct. at 2795-96. In assessing the reliability of a proffered expert’s testimony, a district court’s inquiry under Daubert must focus, not on the substance of the expert’s conclusions, but on whether those conclusions were generated by a reliable methodology. See id. at 590, 595, 113 S.Ct. at 2795, 2797. To assist district courts in making this preliminary assessment, the Court enumerated four non-exclusive factors for determining whether an expert opinion is reliable: (1) whether the expert’s conclusions have been tested or are testable; (2) whether the expert’s conclusions have been published and subjected to peer review; (3) in the case of a scientific technique, the potential or known error rate; and (4) whether the expert’s conclusions have gained general acceptance in the relevant scientific community. See id. at 593-94, 113 S.Ct. at 2796-97. The courts of appeals have applied other factors as well, such as whether the theory or method offered by the expert has been put to any non-judicial use, see Cabrera v. Cordis Corp., 134 F.3d 1418, 1420-21 (9th Cir.1998); In re Paoli R.R. Yard PCB Ligit., 35 F.3d 717, 742 n. 8 (3d Cir.1994), “or whether they have developed their opinions expressly for purposes of testifying,” Daubert v. Merrell Dow Pharms., Inc., 43 F.3d 1311, 1317 (9th Cir.1995) (“Daubert II”). Additional factors may be appropriate in a given case, and a district court enjoys the same “broad latitude” in deciding what are the “reasonable measures of reliability in a particular case” as it does in reaching its ultimate determination of reliability. Kumho Tire, 526 U.S. at 142, 153, 119 S.Ct. at 1171, 1176. Rule 702’s standard of reliability is, however, “exacting,” Weisgram v. Marley Co., 528 U.S. 440, 455, 120 S.Ct. 1011, 1021, 145 L.Ed.2d 958 (2000), and does not, as some pre-Daubert courts held, turn simply on the quality of the proffered expert’s credentials. Compare, e.g., Ferebee v. Chevron Chem. Co., 736 F.2d 1529, 1534 (D.C.Cir.1984) (“On questions such as these, which stand at the frontier of current medical and epidemiological inquiry, if experts are willing to testify that such a link exists, it is for the jury to decide whether to credit such testimony.”), ioith Fed.R.Evid. 702 adv. committee note (2000 Amendment) (“The trial court’s gatekeeping function requires more than simply ‘taking the expert’s word for it.’ ” (quoting Daubert II, 43 F.3d at 1319)). Daubert’s second criterion of “fit” is essentially a requirement of relevance: “Rule 702’s ‘helpfulness’ standard requires a valid scientific connection to the pertinent inquiry as a precondition to admissibility.” Daubert, 509 U.S. at 591-92, 113 S.Ct. at 2796. A proffered expert opinion may fail to meet the fit requirement if it relates to “facts or data that have not been adequately established in the case.” Fed. Jud. Ctr., Reference Manual on Scientific Evidence 47 (1994); see Fed.R.Evid. 702 (as amended) (providing that expert opinion is admissible if “based upon sufficient facts or data”). Thus, “[e]ven if an expert testifies that Substance X can cause the plaintiffs injury, this testimony will not suffice if the plaintiff failed to produce evidence that he or she was exposed to Substance X ... or at a significant level.” Id. at 48. Similarly, where there is expert testimony that a given substance can cause a certain condition, but an exposed plaintiff complains of a different condition, the expert’s opinion, even if reliable, does not fit the facts of the case, is not helpful to the trier of fact, and, thus, is inadmissible. Accordingly, in a toxic tort case, expert testimony on the issue of general causation meets Daubert’s “fit” requirement only if the testimony includes an opinion that (1) exposure to the particular substance at issue, (2) in the dose to which the plaintiff was exposed, (3) for the duration in which plaintiff was exposed, (4) can cause the particular condition(s) of which the plaintiff complains. B. Application of Daubert to Expert Testimony Based on a Review of Existing Medical Literature Plaintiffs’ experts have done no research of their own on the question of whether exposure to xylene or the other organic solvents to which Mr. Amorgianos was allegedly exposed in the amount and for the duration claimed by plaintiffs can cause the crippling peripheral neuropathy and CNS effects Mr. Amorgianos allegedly suffers. Instead, their methodology consists of an extrapolation from existing medical evidence on the relationship between exposure to various organic solvents and various PNS and CNS conditions, buttressed by the temporal proximity of the onset of Mr. Amorgianos’s alleged illness to his alleged exposure to xylene and other organic solvents on the Steinway Street Bridge Project. Fortunately, in Joiner, the Supreme Court provided substantial guidance on the proper assessment of the reliability of expert testimony that is based on extrapolation from the findings of existing medical studies. Because there is conflicting Second Circuit authority on this issue, an extended examination of the Supreme Court, court of appeals, and district court opinions in Joiner is necessary to ascertain the appropriate standards to be applied to this motion. 1. Joiner in the District Court In Joiner, a plaintiff electrician who suffered from lung cancer alleged that he had been exposed to a dielectric cooling fluid which was contaminated with PCBs and other toxins in the course of his work with electrical transformers. Joiner proffered three experts who relied on epidemiological and animal studies to conclude that this exposure to PCBs had caused, or at least promoted, his subsequent development of lung cancer. After conducting a searching review of the data relied on by Joiner’s experts, the district court found that: (1) the authors of some of the epidemiological studies expressly stated that they had found no statistically significant association between PCBs and lung cancer; (2) the other epidemiological studies either did not mention PCBs or involved confounding factors, such as exposure to other toxins, and (3) the experimental studies on mice involved a different type of cancer than that suffered by the plaintiff. See Joiner v. General Elec. Co., 864 F.Supp. 1310, 1322-26 (N.D.Ga.1994), rev’d, 78 F.3d 524 (11th Cir.1996), rev’d, 522 U.S. 136, 118 S.Ct. 512, 139 L.Ed.2d 508 (1997). Stating that it was not persuaded that “th[ose] studies support the ‘knowledge’ the experts purport to have,” the district court excluded the testimony of all three experts and granted summary judgment to the defendant manufacturer. See id. at 1326. 2. Joiner in the Court of Appeals On appeal, the Eleventh Circuit reversed, holding that the district court’s criticisms of the plaintiffs expert testimony went to the testimony’s weight, rather than its admissibility. ' The court of appeals began by noting that the district court’s evidentiary review was at odds with the “ ‘liberal thrust’ ” of Daubert, 509 U.S. at 588, 113 S.Ct. at 2794 (quoting Beech Aircraft Corp. v. Rainey, 488 U.S. 153, 169, 109 S.Ct. 439, 450, 102 L.Ed.2d 445 (1988)), and the Federal Rules of Evidence: It is important for trial courts to keep in mind the separate functions of judge and jury, and the intent of Daubert to loosen the strictures of Frye and make it easier to present legitimate conflicting views of experts for the jury’s consideration. Joiner, 78 F.3d at 530. The Eleventh Circuit then strongly criticized the district court for excluding “the testimony because it drew different conclusions from the research than did each of the experts,” and admonished that under Daubert, a district court should not “make independent scientific judgments on the basis of individual studies”: [T]he gatekeeping responsibility of the trial courts is not to weigh or choose between conflicting scientific opinions, or to analyze and study the science in question in order to reach its own conclusions from materials in the field. Id.; see also id. {“[Daubert ] is not intended to turn judges into jurors or surrogate scientists.”); cf. Maiorana, 52 F.3d at 1137 (warning that “the law does not ‘impose[ ] on [judges] either the obligation or the authority to become amateur scientists’ ” (quoting Daubert, 509 U.S. at 601, 113 S.Ct. at 2800 (Rehnquist, C.J., concurring in part and dissenting in part))). On this latter point, Judge Birch specially concurred: Whether the conclusions advanced from the stated premises in fact follow and the persuasiveness of those conclusions in the ultimate resolution of competing opinions, are questions appropriately left to the finder of fact. Joiner, 78 F.3d at 534-35 (Birch, J., specially concurring); cf. Maiorana, 52 F.3d at 1126, 1131, 1133, 1139 (in scrutinizing the studies relied on by expert, district court improperly “substituted its judgment for that of the jury”). Finally, reviewing the criticisms leveled by the district court against plaintiffs experts, the Eleventh Circuit held: “None of these reasons is sufficient to render an expert’s opinion legally unreliable.” Joiner, 78 F.3d at 532. The Eleventh Circuit, therefore, reversed the district court’s ex-elusion order, stating the “tests and criticisms cross-examination would supply,” were the proper device for treating such deficiencies in expert testimony. Id.; cf. Maiorana, 52 F.3d at 1132 (district court’s criticisms of expert’s testimony went to weight and should have been dealt with through “the traditional devices of ‘[vigorous cross-examination, presentation of contrary evidence, and careful instruction on the burden of proof” (quoting Daubert, 509 U.S. at 596, 113 S.Ct. at 2798)). 3. Joiner in the Supreme Court In an eight-to-one decision authored by Chief Justice Rehnquist, the Supreme Court squarely rejected the Eleventh Circuit’s reasoning and held that the district court’s analysis was entirely proper under Daubert. The Court clarified that it is “within a District Court’s discretion to conclude that the studies upon which the experts rel[y][are] not sufficient, whether individually or in combination, to support their conclusions” on causation. Joiner, 522 U.S. at 146-47, 118 S.Ct. at 519. After reiterating that Daubert requires district courts to screen out unreliable expert testimony, see id. at 142, 118 S.Ct. at 517, the Court conducted an illuminating step-by-step review of the district court’s analysis of the studies relied upon by Joiner’s experts. Agreeing with the district court at each step, the Court placed special emphasis on the fact that the authors of two of the epidemiological studies relied on by the plaintiffs experts were unwilling to conclude that those studies established a causal link between PCB’s and lung cancer. See id. at 145, 118 S.Ct. at 518 (“Given that Bertrazzi et al. were unwilling to say that PCB exposure had caused cancer among the workers they examined, their study did not support the experts’ conclusion that Joiner’s exposure to PCBs caused his cancer.”); id. at 145, 118 S.Ct. at 519 (noting that increased incidence of lung cancer found in second study “was not statistically significant and the authors of the study did not suggest a link between the increase in lung cancer deaths and the exposure to PCBs”). The Court upheld the district court’s rejection of the two remaining epidemiological studies on grounds of “fit”: one was limited to a particular kind of mineral oil and did not mention PCBs; the other involved PCB-exposed workers who had also been exposed to numerous other potential carcinogens. See id. at 145-46, 118 S.Ct. at 519. In another significant illustration of the “fit” requirement, the Court also rejected the animal studies upon which Joiner’s experts relied. The Court noted that the studies in question involved infant mice that had developed alveologenic adenomas after massive doses of PCBs were injected directly into their stomachs and peritoneums; Joiner, however, suffered from small-cell carcinoma, an entirely different disease. See id. at 144, 118 S.Ct. at 518. Explaining that the “issue was whether these experts’ opinions were sufficiently supported by the animal studies on which they purported to rely,” the Court held that “[t]he studies were so dissimilar to the facts presented in this litigation that it was not an abuse of discretion for the District Court to have rejected the experts’ reliance on them.” See id. at 144-45, 118 S.Ct. at 518. Most significantly, the Supreme Court definitively rejected the Eleventh Circuit’s reasoning that a point-by-point examination of the data relied on by experts runs afoul of Daubert’s admonition that a district court’s “focus ... must be solely on the principles and methodology, not the conclusions they generate,” Daubert, 509 U.S. at 595, 113 S.Ct. at 2797: Conclusions and methodology are not entirely distinct from one another. Trained experts commonly extrapolate from existing data. But nothing in either Daubert or the Federal Rules of Evidence requires a distñct couH to admit opinion evidence which is connected to existing data only by the ipse dixit of the expert. A court may conclude that there is simply too great an analytical gap between the data and the opinion offered. That is what the District Court did here, and we hold that it did not abuse its discretion in so doing. Joiner, 522 U.S. at 146, 118 S.Ct. at 519 (emphasis added) (citing Turpin v. Merrell Dow Pharms., Inc., 959 F.2d 1349, 1360 (6th Cir.1992) (“The analytical gap between the evidence presented and the inferences to be drawn on the ultimate issue of [causation] is too wide. Under such circumstances, a jury should not be asked to speculate on the issue of causation.”)). 4. Subsequent Second Circuit Authority A recent Second Circuit decision confirms the bounds of a district court’s discretion to exclude unreliable expert evidence as announced in Joiner. See Washburn v. Merck & Co., 213 F.3d 627, 2000 WL 528649 (2d Cir.2000) (Table). In Washburn, the plaintiffs experts opined that the defendant’s rubella vaccine had caused her to develop arthropa-thy, arthralgia and chronic fibromyalgia. The Second Circuit upheld the exclusion of the plaintiffs experts and the granting of summary judgment to the vaccine manufacturer, where the experts’ opinions were based “on little more than temporal correlation between [the plaintiffs] vaccination and the onset of symptoms.” Id., 213 F.3d 627, 2000 WL 528649, at *2 (citing Cavallo v. Star Enter., 892 F.Supp. 756 (E.D.Va.1995), aff'd in relevant part, 100 F.3d 1150 (4th Cir.1996); Conde v. Velsicol Chem. Corp., 804 F.Supp. 972, 1023 (S.D.Ohio 1992), aff'd, 24 F.3d 809 (6th Cir.1994)). In particular, the Second Circuit rejected one expert’s extrapolations from the medical literature as unreliable where, inter alia, (1) those studies explored a link between the vaccine and arthritis, rather than the specific chronic joint conditions alleged by the plaintiff, and (2) even “the evidence linking the vaccine with arthritis [was] derived mainly from anecdotal reports and small population studies with few controls.” Id. Another of plaintiffs expert’s opinion on causation was ruled to have been properly rejected where it “did not emanate from his own research in the field, but rather was developed for the purposes of litigation.... [The district court] reviewed the studies and articles that [the expert] used to conclude that there is a causal relationship between [the defendant’s vaccine] and chronic joint conditions and found that none was a large-scale epidemiological study and most were either anecdotal, or did not involve [the defendant’s vaccine].” Id. Earlier Second Circuit decisions that suggest such an examination of the authorities relied upon by a plaintiffs experts oversteps the bounds of a district court’s discretion under Daubert,e.g., Maiorana, 52 F.3d at 1133, 1137, 1139, therefore, no longer appear vital in the wake of Joiner. 5. Relevant Epidemiological Principles In addition, in assessing whether plaintiffs’ experts have reliably extrapolated their causal hypothesis from the existing medical evidence and the significance of temporal proximity of plaintiffs alleged exposure and illness, the fundamental principles of epidemiology, which are now becoming well known to the courts, provide additional guidance. There are several different forms that epidemiological studies take in the areas of occupational medicine and toxicology. These various research designs differ in the evidentiary weight they lend to a hypothesis that exposure to a given substance causes a given condition. See Environmental & Occupational Medicine 44 (William N. Rom ed., 3d ed.1998) (cited by Dr. Rutchik as authoritative); Reference Manual, supra, at 131-38. The epidemiological studies cited by plaintiffs’ experts fall into two general categories: (1) uncontrolled case studies or case reports; and (2) cross-sectional studies. See infra Appendix tbls. 1-3. “An uncontrolled case study, or case-series report, is not actually a formal epi-demiologic investigation but simply the identification of an unusual occurrence or disease.” Rom, supra, at 44. The principal function of such reports is to alert health professionals to the possibility of occupational causes of disease. See id. at 45. “In an occupational cross-sectional study, a survey is conducted to determine and compare the prevalence of disease or health status between groups of workers classified with respect to exposure status.” Id. One of the main limitations of cross-sectional studies is that they are confined to actively employed workers who have chosen to participate; “[w]orkers who have left employment for reasons that might be related to exposure and those who choose not to participate are excluded.” Id. Because of their inherent limitations, these two study designs “usually represent preliminary or pilot investigations used to screen