Document MoGZKbvp269pJNYNYXmn33QyL

Message From: Pat Quinn [pquinn@theaccordgroup.com] Sent: 11/20/2017 6:54:06 PM To: Beck, Nancy [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=168ecb5184ac44de95a913297f353745-Beck, Nancy]; Keigwin, Richard [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=151baabb6a2246a3a312fl2a706c0a05-Richard P Keigwin Jr] CC: Goodis, Michael [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=50ed0b92dc4945b7a808fe8dbc9224f0-Michael Goodis]; Weiss, Steven [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=6ce04987a3784f21985f65e96c220b84-Weiss, Steven]; Bill McCormick [william.mccormick@clorox.com]; Diane Boesenberg [diane.boesenberg@rb.com]; Hal Ambuter [hal.ambuter@reckittbenckiser.com]; Jan Dhonau [dhonau.jl@pg.com]; Julie Timberman [julie.timberman@clorox.com]; Mary Joy Stuart [stuart.m@pg.com]; Pat Quinn [pquinn@theaccordgroup.com]; Peggy Hartness [peggyh@theaccordgroup.com]; Sean Broderick [broderick.sp@pg.com]; Teresa Moore [moore.tc@pg.com] Subject: RERESPONSE REQUESTED- Briefing on Proposal to Exempt from Tolerance FDA Approved Food Additives ( Flavorings ) for Use as Fragrance Ingredients in Food Contact Antimicrobials Attachments: FSF Position Paper 5-15-2017 EO 13777.pdf; wcm edits OPP IRG Nov 2 2017 F.PPTX Importance: High Flag: Follow up Nancy/ Rick, I hope you are both well and preparing for Turkey Day L.and a well -deserved break.... My Innovation Reform Group ( Clorox, P&G, Reckitt Benckiser) has worked collaboratively with OPP for the last 18 years on policy and process reforms that have yielded benefits to EPA and the regulated community. One area of concentration has been fragrances and how best to provide EPA with data on fragrance ingredient safety in order that registrants making sanitizers and disinfectants might make changes efficiently and quickly without any compromise to public health protection. The work of the IRG companies along with the fragrance industry resulted in the EPA Fragrance Ingredient List ( FIL) containing about 1500 approved fragrance ingredients and maintained by NAB in RD and the EPA Fragrance Notification Program , which has worked flawlessly for nearly a decade saving registrants and OPP precious resources. The IRG submitted a proposal ( attached ) under E.O. 13777 suggesting that EPA use existing authority to exempt from tolerance requirements about 1100 FDA approved direct and indirect food additives. These are naturally derived flavoring ingredients reviewed and approved by independent expert panels ( JECFA, FEMA ); these are commonly consumed by all of us in our daily diet. The 1100 represent a substantial portion of the EPA FIL and would allow registrants making food contact sanitizers/disinfectants to continue to sell fragranced products demanded by their customers for use in the kitchen. Why is this necessary ? Simply put, OPP's view of residues left from food contact disinfectants has changed. Previously, it was assumed that - if a potable water rinse was required--no residues of concern would remain. That is no longer the case; the effect of a water rinse has been diminished and worst case residues are assumed. In addition , OPP's definition of a " food contact surface" has been substantially expanded. Virtually no fragrance ingredients currently have EPA tolerances or tolerance exemptions. The process of obtaining them for 1500 ingredients is daunting, lengthy, expensive and would result in no risk reduction or public health benefit. If NAB completed one tolerance review/ week, the process could take 22 years and cost tens of millions of dollars. FDA has reviewed the safety of these food additives; they are commonly consumed; accepting FDA's science instead of conducting a duplicative review just makes good sense. The IRG briefed RD ( Mike) and AD (Steve) on 11/2 on the proposal ( see attached PP slides ). We would now propose to brief the two of you with RD, AD and perhaps OGC present. The following dates are suggested : Monday 12/11 Sierra Club v. EPA 18cv3472 NDCA Tier 12 ED 002061 00039542-00001 Tuesday 12/12 Wednesday 12/13 This is a science based initiative that will reduce burdens on EPA and the private sector; avoid duplicative reviews by sister Agencies; allow limited OPP resources to be more effectively directed while protecting public health. We won't waste your time ! Happy Thanksgiving and I look forward to hearing what might work for you on those dates. Pat Sierra Club v. EPA 18cv3472 NDCA Tier 12 ED 002061 00039542-00002