Document ZJrk2gogowypNR4G5ay6xNdw8

Message From: Sent: To: CC: Subject: Beck, Nancy [/0=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=168ECB5184AC44DE95A913297F353745-BECK, NANCY] 12/6/2017 4:48:15 PM Pat Quinn [pquinn@theaccordgroup.com] Keigwin, Richard [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=151baabb6a2246a3a312fl2a706c0a05-Richard P Keigwin Jr]; Keller, Kaitlin [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=d7a6bl5adfd745c6adalcl21dec27ac4-Keller, Kai] Re: Meeting Request-Efficacy Working Group on OECD Method Implementation Issues Thanks. Nancy B. Beck, Ph.D., DABT Deputy Assistant Administrator, OCSPP [IlllliZIIlJ P: 202- 564-1273 Beck.Nancy@epa.gov On Dec 6, 2017, at 11:44 AM, Pat Quinn <pquinn@theaccordgrQup.com> wrote: OK...understood. These companies are all here then for a trade association meeting so I was trying to take advantage of that, but I can work with Kaitlin on alternative dates. Pay Sent from my iPhone On Dec 6, 2017, at 10:45 AM, Keigwin, Richard <Keigwin.PJehard@8pa.goy> wrote: Pat-- Unfortunately, neither of those dates work for me. I'm scheduled to be out of the office that entire week, other than Monday, January 8th. I believe Nancy is out of the office for at least part of that week, as well. -Rick From: Pat Quinn [mailto:pquinn@theaccordgroup.com1 Sent: Wednesday, December 06, 2017 10:33 AM To: Beck, Nancy <B8ck.N3ncy@ep3.gov>; Keigwin, Richard <Keigwin.PJchard@8p3.gov> Cc: Keller, Kaitlin <keller.kaitlin@epa.gov> Subject: Meeting Request-Efficacy Working Group on OECD Method Implementation Issues Importance: High Nancy/ Rick, the companies comprising the Efficacy Working Group ( ..the other "EWG" (;) have asked me to request a meeting with both of you to discuss concerns they have regarding OPP's plans to implement the OECD Quantitative Efficacy Method for Bacteria and TB during the first few months of 2018. Those companies are : Sierra Club v. EPA 18cv3472 NDCA Tier 12 ED 002061 00050182-00001 1) <!--[if !supportLists]-x!--[endif]->Ecolab 2) <!--[if !supportLists]--x!--[endif]->Reckitt Benckiser 3) <!--[if !supportLists]-x!-[endif]->P rocter & Gamble 4) <!--[if !supportLists]-x!-[endif]->Lonza 5) <!--[if !supportLists]--x!-[endif]->Stepan 6) <!--[if !supportLists]-x!-[endif]->M ason These companies and others have expressed longstanding concerns about the readiness of the OECD Method for implementation; its reproducibility, and how the new method will co-exist with well-established efficacy methods ( AOAC Use Dilution Method, EN -13697) currently in place to test the efficacy of antimicrobial products. The potential market impact of the OECD Method is enormous since certain chemistries ( Quaternary Compounds, Phenols) which consistently pass the UDM test for hospital disinfectants regularly fail the OECD Method; these compounds comprise the majority of hospital disinfectants used in the U.S today. An estimated 75% of all concentrate disinfectants currently marketed will fail the OECD Method and as many as 1500 EPA registered disinfectant products will be jeopardized, requiring reformulation with Active Ingredient levels at much higher concentrations. The EWG companies have a long historical involvement with the OECD Method , participating is test c o lla b o ra te s and testifying in Paris in 2011 at the OECD when concerns expressed by the German and French delegations delayed the method's full approval. We have worked closely with BEAD and AD on these matters and continue that collaboration. With a Guidance Document implementing the OECD Method for use in the U.S. now imminent, we want to ensure that broad industry concerns are expressed clearly and in a timely fashion. To that end, the EWG companies are requesting a one hour meeting with you for either January 9th or January 11th. W e could meet anytime between 9am -5pm on 1/9 and anytime between 1-5 pm on January 11th. Thanks in advance for your consideration of this request and we look forward to the discussion. Pat 202-841-3930 Sierra Club v. EPA 18cv3472 NDCA Tier 12 ED 002061 00050182-00002