Document J1GqRK20xVx7k02ngp5b4a7v

JOIVM ft KftlLftft ^CftOMC M. mCCRMAM CHAOLKI M MftftMAft WI4.CUAM lOftOnClANI, J* AftftftT ft TlftftwAW MAICQU* O. MACAffTMU* fC v. I>C> u*T'w w cfteev'O JOMN ft. CLOACA CAftOLC e HANKlS MtCHAlk r. MOMO*t LAftPTr ft. ftOWOMOM JOHN ft. 9U0ICI CHftlfttlMft A. MCAftMftft ftHtftlfr ft. fUJIMOTO ftCTftft 4 hmCIUI LAWftftMCC A H*40ftiN CCftOftAn SNUft TAiwAftft C. OOUOLAft JAftACTT CDWAftO XONWER JONATHAN ft LCVIMft 1HCIU A. MIVbAft UI9CU '* utt m. mt*H AMOCUNA C- li ftWAA-C TIWOTMT 0NOWN iLCNft ftlMOCl WftlpkCft LAW OEFXCKS Keller and Heckman 1150 17TM STREET, N. W. SUITE lOOO WASHINGTON, D. C. 30035 (202) a4S7*HOO April 7, 1983 Cl.tcep'CP (**) CAftVC AOOftftftft"ttWAP" ftfTftW'ft DlftftCT ftlAi. NUMAftl 202/457-1110 Dr. Sanford Miller Director, Bureau of Foods HFF-1, Room 6819 Food and Drug Administration 200 C Street, SW Washington, DC 20204 Re: Polyvinyl Chloride Packaging Materials; Request for Marketing Data Dear Dr. Miller: In a letter dated August 31, 1982, signed by Mr. McCowin and addressed to Mr. Jerome H. Heckman, General Counsel for The Society of the Plastics Industry, Inc. (SPI), the Food and Drug Administration asked for any available current and projected future market data for vinyl chloride polymers as food contact materials. This request was repeated in your letter dated December 27, 1982. Since adequate data of the type you requested are not available, vinyl chloride resin manufacturers, through the SPI Vinyl Institute, have agreed to conduct a survey to obtain the requested information. In this connection a draft survey form has been developed. We are hereby requesting that the Food and Drug Administration review it and provide its recommendations for either improvement of the form or conduct of the project so that the results obtained may be of the maximum utility. Attached hereto is a copy of the draft survey form. Our plan is to send it to the major resin manufacturers. You will note that it is intended to elicit estimates or current and projected future sales (in pounds of resin) for different categories of vinyl chloride polymers intended for use in contact with various classes of foods. This information will be supplemented by consultation with VVC 000006875 Dr. Sanford Miller April 7, 1983 Page Two Keller and Heckman packaging experts to determine the weight of resin utilized in typical packaging configurations for the various com binations of polymer types and foods. Finally, utilizing the so-called market basket surveys, the relative proportion of food in each of the various classes packaged in PVC will be calculated leading to what we believe will be a useful consumption factor. The industry is committed to a prompt response to the survey questionnaire. Accordingly, we hope your staff will be able to provide its recommendations now so that the information requested in Mr. McCowin's August 31, 1982, letter can be provided with no unnecessary delay. Enclosure V\/Q DO NOT COMPLETE--FOR COMMENT ONLY DRAFT SURVEY FORM General For each class of foods, enter your estimate of the total market (not your company's share) for each of the PVC products shown. The estimate should be in pounds of resin only, not of formulated end-product. For example, if an end-product contains 18 parts per hundred of resin (phr) of additives, report only the 100 lbs of resin, not the 118 lbs of end-product. Please provide your estimate for the current market indicating the year to which "current" relates, and for the market 5 years after positive FDA action. Please mark with an asterisk (*) those entries for which you expect to market resins. Definitions For this survey, use the following definitions: "Rigid" means a product with a modulus greater than 100,000 lbs per square inch (psi). "Semirigid" means a product with a modulus be tween 10,000 psi and 100,000 psi. "Flexible" means a product with a modulus less than 10,000 psi. "Plasticized" means a product with more than 10 phr of external plasticizer. "Film" means a layered product less than 0.010 in. thick. "Sheet" means a layered product 0.010 in. or tmcker. vvc 000006377 2 Codes for Different FVC Products Product Code Rigid and semirigid film Rigid and semirigid sheet Rigid and semirigid containers [All types: bottles, jars, cans, etc.] Flexible, Flexible, Flexible, Flexible, Flexible, plasticized film plasticized sheet plasticized other unplasticized film unplasticized other Coatings Plastisols and organosols A B C D E F G H J R Food Classes Fluid Milk includes whole, low fat, skim milk. Processed Milk Products includes fluid products such as butter milk, yogurt, chocolate milk. Cream includes half and half, light cream, heavy cream, sour cream. Ice Cream includes sherbert, frozen yogurt, frozen custard. Meat, Fresh includes all varieties (beef, pork, poultry) and cuts (steak, roast, ground). Meat, Frozen includes all varieties (beef, pork, poultry) and cuts (steak, roast, ground). Meat, Cured includes all types of wurst, smoked meats, hot dogs. Fish includes fresh, frozen, cured (smoked). VVC 000006878 3 Canned Meats and Fish includes Spam, canned tuna, canned corned beef. Oil includes mayonnaise, salad dressing. Butter includes margarine, other table spreads. Shortening includes lard, hardened oils. Non-Alcoholic Beverages includes cola, carbonated drinks, fruit drinks, juices (not frozen). Alcoholic Beverages flow alcohol] includes beer, wine, forti fied wine. Alcoholic Beverages Thigh alcohol] includes whiskey, cordials (40-proof or greater). Fruits and Vegetables, Fresh Fruits and Vegetables, Frozen includes frozen juices. Fruits and Vegetables [in cans or jars] includes meat-contain ing stews, chowders and soups, vacuum-packed nuts, ketchup, tomato juice. Nuts, Shelled includes everything but "vacuum packed." Powdered Dry Foods includes "instant" soup, bouillon, powdered milk, powdered chocolate drink, sugar, flour. Cereal Grains includes oatmeal, farina, grits. Cereal [Ready-To-Eat] includes corn flakes, shredded wheat, bran flakes, sugared flakes with raisins. Bread includes all types of bread, biscuits, pasta, noodles. Tea, Coffee, Cocoa includes tea leaves, ground and instant cof fee, cocoa powder. Desserts include cake, pastry, pie (incl--^..^ frozen), c^ndy. Preserves include jams, jellies, marmalade, -"-ut butt--. All Other Frozen Foods and Meals VVC 000006879 4 Spices, Seasonings, Condiments includes pepper, salt, cinnamon. oregano, mustard. Water includes spring water, mineral'water. Other [Please Specify] VVC 000006980 DO NOT COMPLETE--FOR COMMENT ONLY .i FOR RACE POOD CLASS, ENTER TOUR ESTIMATE OP THE TOTAL MARKET (NOT TOUR COMPANY'S SHARE) ORDER TEE APPROPRIATE PVC PRODUCT CODE IN THOUSANDS OP POUNDS OP RESIN PER TSAR. IP ALL TOE "CURRENT" ESTIMATES ARB BASED UPON TBS SAME TIME PERIOD* PLEASE STATE THE TEAR (8) AT THB BOTTOM OF THE TABLE. IF DIFFERENT TIME PERIODS ARB INVOLVED, PLEASE STATE TER YEAR (9) IN THE PARENTHE SIS. Pt^ASE MARK HITE AN ASTERISK () THOSE ENTRIES FOR WHICH YOU EXPECT TO MARKET RESINS. Food Class rise Period MARKET ESTIMATE. M LBS OP RESIN PER TEAR PVC Product TYPi ABCDEFCBJK Fluid Milk Processed Milk Products Cream Ice Cream Meat, Fresh Meat, Frozen Meat, Cured Current ( 5 Year Current { 5 Year Current ( 5 Year Current ( 5 Year Current ( 5 Year Current ( 5 Year Current ( 5 Year ) ) ) ) ) ) ) 00 o rood Class Time Period 7 sh C nn >`l H <ils aii'l Pish Oi l 8 tt !C Shortening Non-Alcoholic Beverages Alcoholic Beverages [low alcohol) Alcoholic Beverages [high alcohol) Curr *.t [ 5 Yr \r Current ( 5 Year Current ( 5 Year Current ( 5 Year Current ( S Year Current ( 5 Year Current ( 5 Year Current < S Year ) ) ) ) ) ) ) ) 2 FVC product Typo rkABC 0 GBJ 0 K <c o ?8B900000 VVC 0 0 0 0 0 6 8 8 3 Food Clans Tle Peclod Fruits and Vegetables, Fresh F'Uits and Vegetables, Frozen Fruits and Vegetables [in cans or jars) Nuts, Shelled P wil iret1 i ry F > Is C c p 11 0 'ins C t e 11 [ '1 ady-'1 - -Eat J R earl Current ( 5 Year Current < 5 Year Current ( 5 Year Current < 5 Year Curr > t ( "> Y> w :ur i < r> Y- r Current ( 5 Yp.ir Current ( 5 Year ) ) ) ) ) ) ) 3 ABC PTC Product Type DBF OBJ K Pood Class Time Period Tea, Coffee, Cocoa Desserts Preserves All Other Frozen Foods and Meals Spices, Seasonings, Condiments Mater Otner (Please Specify) ----------- --------- -------- Current ( S Year Current { 5 Year Current ( 5 Year Current ( 5 Year Current ( 5 Year Current ( 5 Year ) ) ) ) ) ) Current ( 5 Year Current ( 5 Year f'urr' nt ( ' Ye i ) ) > < O< 4 ABC , FVC Product Typo DB P 6 i B J K ^88900000 i / '</? c/5 7/_____ d^A ck> UJG/CKSO AA s JLi fy&y# t*tfsx4fy>&9c3. e>o?7^ // ' a**~&*&Q c-*^a***s^ r^O Jfcl &Q<b*~oJLyo^ J Sf- &ObJLu^ -- /*f J/6//S J S$T CtffU/dbis) UUA*JJ(J - J^a/^UU '?<-&'Sk4.L//''ZjuO d'C /U.<^v-a^ Sx) 'Zvi (& Co 7:4 c -s:C7A> *ro9 Co c;c& ^ ^-T& ` , ^4 V - VVC 000006885