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Jay Vroom [JVroom@croplifeamerica.org] 6/17/2017 11:44:44 AM Beck, Nancy [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=168ecb5184ac44de95a913297f353745-Beck, Nancy]; janet collins [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=usera98e8fe5]; Bennett, Tate [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=lfa92542f7ca4d01973bl8b2fllb9141-Bennett, El] Mary Jo Tomalewski [mjtomalewski@croplifeamerica.org]; Beau Greenwood [BGreenwood@croplifeamerica.org]; Cindy Baker-Smith (csmith@gowanco.com) [csmith@gowanco.com]; Hunt Shipman [hshipman@cgagroup.com] Re: Follow up materials
Nancy and Tate (added on this reply)-- I want to add my thanks for your time and useful conversation. And add two other points:
PRIA (PREA) Reauthorization-- this continued to see additional twists even after our meeting this week and we should stay in close communication as it moves forward. I mentioned the benefit of a good "score" by CBO for the current legislation as an added benefit to the package as introduced. I'll ask, by cc of this to Beau and Hunt Shipman, that our team get you more details about the current CBO score and exchange some further thoughts about any risks from significant change to the language as introduced vis a vis the favorable score.
ESA--you mentioned planned interagency meetings this coming week on the issue--please keep us in the loop and we will do the same for you.
Hope you're having a great weekend.
Jay
Jay Vroom President & CEO Crop Life America 1156 15th Street, NW Suite 400 Washington, DC 20005
Ex. 6 |
Vroom@cropiifeamerica.org www.croplifeamerica.org
From: Nancy Beck <beck.nancy@epa.gov> Date: Friday, June 16, 2017 at 1:46 PM To: Janet Collins <icoyins@cropHfeamerica.org> Cc: Jay Vroom <jvroom@croplifeamerica.org>, Mary Tomalewski <mitomalewski@croplifeamerica.org>, Beau Greenwood <bgreenwood@cropiifeamerica.org>, Cindy Smith <csmith@gowanco.com> Subject: RE: Follow up materials
Thank you Janet. It was good to meet everyone and I appreciate you following up with all this information.
Regards,
Sierra Club v. EPA 18cv3472 NDCA
Tier 3/4
ED 002061 00043729-00001
Nancy
Nancy B. Beck, Ph.D., DABT Deputy Assistant Administrator, OCSPP
Ex. 6....|
beck.n3ncy@ep3.gov
From: Janet Collins [mailto:iconins@croplifeamenc3 .orgl Sent: Thursday, June 15, 2017 8:16 PM To: Beck, Nancy <Beck.N3ncy@ep3.gov> Cc: Jay Vroom <JVroom@cropiifeamerica.org>; Mary Jo Tomalewski <mjtQm3 lewski@crQplifeamerica.org>; Beau Greenwood <BGreenwood@croplifeamerica.org>; Cindy Baker-Smith (csmith@gowanco.com) <csmith@gowanco.com> Subject: Follow up materials
Nancy- thanks very much for taking an appointment yesterday with CropLife America (CLA) CEO and President, Jay Vroom; CLA member, Cindy Baker Smith from Gowan Company; Executive Vice President, Government Relations, Beau Greenwood; and me to discuss concerns our members have regarding EPA/HED use of epidemiological data and a literature review supporting the EPA position, in spite of the fact that the Administrator has questioned the use of epidemiologic study outcomes in human risk assessment. We are concerned that the continual posting of such documents on open dockets, as supporting documents in those dockets, creates a record as to where EPA is acting and regulating with respect to its approach to integration of data sources and weight of evidence in human risk assessment.
Attached please find documents that provide some perspective as to the approach EPA is taking, and CLA objections to such approach:
<!--[if !supportLists]-x!--[endif]->CLA 2010 petition to EPA, requesting guidance from EPA on use of epi studies prior to any regulatory use of such studies in human risk assessment;
<!--[if !supportLists]-x!--[endif]->EPA response letter, denying the petition, but stating that EPA would put out guidance on the topic for notice and comment which has not occurred;
<!--[if !supportLists]-x!--[endif]->CLA 2016 petition requesting EPA not use such epidemiologic studies until EPA developed criteria for use and design of the studies- November 2016, no response to date;
<!--[if !supportLists]--x!-[endif]-->2015 EPA literature review to support EPA/HED use of epi studies in organophosphate [OP (and by association, other OPs)] human risk assessment;
<!--[if !supportLists]--x!-[endif]-->2016 EPA literature review updated from 2015, posted to dockets in late May, 2017; and,
<!--[if !supportLists]--x!-[endif]-->EPA's 2016 Framework (updated from 2010) for integration of epidemiological studies- posted on the EPA website on December 28 2016, with no notice or comment.
After your review of these documents, should you wish to discuss them or ask specific questions, please let me know and we will arrange a time to meet as quickly as convenient for you.
Once again, thanks for the time you spent with us on this important issue.
My best,
Janet E Collins, Ph.D., R.D. Executive Vice President, Science and Regulatory Affairs CropLife America 1156 15th Street, NW; Suite 400 Washington DC 20001
Ex. 6
Sierra Club v. EPA 18cv3472 NDCA
Tier 3/4
ED 002061 00043729-00002
Ex. 6
Sierra Club v. EPA 18cv3472 NDCA
Tier 3/4
ED 002061 00043729-00003
