Document a42aDVKo2xjLvggZv5QyrY9Qy
NOV 6 1S72
JOSEPH E KELLER JEROME II HECKMAN CHARLES M MEEHAN' WILLIAM M nORCHESA.VI, ,) R ROPER r K TU'HNAN WAYNE V, ULAC'K DAVID L HILL MARTIN W BERCOVICI lklanu .j ulair PETER M NEMKOV
law ofitcbs
KE-LLun and TIeckman
1150 17TM STREET, N W 'sUlI'E JOOO
WASHINGTON, D-C. liOOHO
November 2, 1972
Dr. Karl A. Hochschwender American Hoechst Corporation Route 202-206 North Bridgewater Post Office Box 2500 Somerville, New Jersey 03876
TET.LTHOVE 12012 1206-127 00 CABLE ABDKrss 'K l-'l MAN'
Re:
The Society of the Plastics Industry, Inc. Food, Drug and Cosmetic Packaging Materials Committee Meeting; December 15, 1972
Dear Karl:
I am very pleased to advise you that, im mediately after our telephone conversation today, I was in touch with Dick Ronk, the Director of the Division of Petitions Processing of the Food and Drug Administration, who just as promptly accepted my in vitation to attend the next meeting of our Food, Drug and Cosmetic Packaging Materials Committee.
By means of their copies of this letter, I am advising all of the members of the Committee that Mr. Ronk will be with us. I might add that I feel reason ably certain they will find a discussion of his plans for improving FDA's processes and any other comments he makes most refreshing. George Ingle and I recently had occasion to appear on a program with Mr. Ronk in Philadelphia, were with him for quite some time there after, and fully believe that he has the desire and the capability to bring about real improvements in the overall indirect food additives regulatory area. This is why we thought it would be a good idea to invite him to our next session which we hope will be well attended.
Incidentally, I realize full well that the Committee has been subjected to "Promises, Promises" by other FDA officials in the past but I am sure all
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Dr. Karl A. November 2, Page Two
Hochschwender 1972
would agree that we must continue to try for something definitive to alleviate the present burdens imposed by the Food Additives Amendment. We are hopeful that Mr. Ronk may at least point us in some new directions towards this end.
As you are also aware, but simply so that the other members of the Committee will be informed, work is under way to complete the full Agend. for the December 15 session. It will probably be one of the longest ones we have ever had because of the many FDA and related legislative and agency actions that have ' been taking place since our last meeting. In any event, we hope this letter will serve to let the Committee know that you and we are preparing the Agenda so that it can be sent out within the next two or three weeks.
cc:
SPI Food, Drug and Cosmetic Packaging Materials Committee
ASI-PR 0001235
LAW OI'I'ICLS
JOSEPH E KELI.EU
JEROME II, If EC K MAN
CflAim-s M MEEHAN'
WILLIAM Id DORGHESANI. JR
ROBERT U TIEKNAN
WAYNE V BLACK David l hili.
MARI in W- DERCONlCl
LKLAND
H7 AIR
PETER M NEMKOV
Kellee and Heckman
ilflO 17+" STREET, N w
WASHINGTON, D. C 2QOHG
November 2, 1972
Mr. Richard J. Ronk Director Division of Petitions Processing Office of Compliance Bureau of Poods Food and Drug Administration Room 5827 (BF-330) 200 C Street, S.W. Washington, D. C. 20204
C AJ3LE ADDRESS ' K I I MAS
Re:
The Society of the Plastics Industry, Inc. Food, Drug and Cosmetic Packaging Materials Committee Meeting; Decemb-. r 15, 1972
Dear Mr. Ronk
Following up on our telephone conversation of today, I am very grateful to you for accepting our in vitation to attend the referenced meeting of the Food, Drug and Cosmetic Packaging Materials Committee of The Society of the Plastics Industry, Inc.
I believe I neglected to mention the point when we talked so let me note here that, as has become customary in connection with pre\lous sessions of our group attended by FDA Staff members, you can certainly feel free to bring any of your associates you would like to have present. All that I ask in this respect is that you give me a little advance notice about who will be on hand so that we can make certain the luncheon and seating arrangements are satisfactory.
The meeting will be held at the Shoreham Hotel and we would hope that you might perhaps be on hand by about noon so that you could have lunch with the group and give us the benefit of your thinking on cur rent FDA policies and problems relating to the regula tion of indirect food additives. As a result of our recent joint appearance at the industry meeting in Philadelphia and our subsequent personal conversations, I suspect that you are well aware of the areas within
ASI-PR 0001236
Mr. Richard J. Ronk November 2, 1972 Pago Two
your expertise which would be of primary interest. Incidentally, please understand that we will in no way be expecting a formal presentation of any type. What is desired is the benefit of your informal views on what is being done, and what more can be done to improve the regulatory processes bearing on indirect food additives.
Among other things, I am sure the membership of the Committee would like to know about the prospects for reviving activity which might bring about adoption of some version of the so-called "Ramsey proposal." Also, everyone would certainly be interested in having your thoughts about the status and outlook as regards the outstanding prior sanctions listing, generally recognized as safe, and colorants for plastics rulemaking proposals. You might also want to mention any difficulties you and your Staff are encountering with the new burdens placed upon you as a result of such statutory provisions as the Freedom of Information Act and the National Environmental Policy Act.
I hope you will realize that I have listed these topics only to give you some idea of the explicit interests of our Committee. It certainly is not my intention to try to limit anything you might want to discuss, nor to impose a burden upon you to cover sub jects which you do not feel can be commented upon ap propriately. It is our hope, however, that there will be a mutually beneficial exchange of ideas on some or all of these matters.
If past indications can be relied upon, there will probably be sixty or so members of our Committee on hand, representing all of the member plastics resins companies, and a great many end-product producers of food packaging materials. We will see to it that there are self-introductions at the luncheon so that you will know precisely who is in your audience. I can tell you that this SPI Committee has now been in existence for more than fifteen years and is rather well informed about the regulatory scene so you will not have to be concerned about any backgrounding on the basics.
0001237
Mr. Richard J. Ronk November 2, 1972 Page Three
As the time for the meeting draws a bit closer, you can be sure that I will be in touch with you to inform you more specifically about our plans, and to make any special arrangements you would like. In the meantime, thanks again for accepting the invitation so promptly and please feel free to call me at anytime if you have any questions about the nature of our group, or any other aspect of the meeting.
ASl~pR 0l238
[l-'or Your Informatioi
Tito Fe*s7or,'iI *Mai*v
THE IVAETIINGTON POST r;iU,.*y. av-. ?, 10:: jr
Nader Study Orem r hk runs Into Delay
roG to baking chickens, Shn is piithalate plasticizers, numer [for tests given Jan fi Thos'1 re
concerned lh."t they mieh> con ous petitions ere involved di ceived by Dec. 23 will be te'ied
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tain a toxic extract (phth, late rectly or indirect]-,- and s-w- on Fob. 10 and those pest* ester) which is imed to make oral wicks or possibly several .marked by Jan, 26 will b#
[plastic more elastic.
montlts would be required to lasted March 10. Aprdirr,;ions
Mike Causey
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Dr, Silborgclri said that "-ip 'error, through cr.ch of the pe deceived after Jan, I'*', will not
plastic baps used to store hu titions to extract toxicological be considered.
man blood were found to con data.
j Interested students should
tain the phfhaiate, which, "like "If you desire toxicological pick i p CSC announcement
certain pesticides, seeks c,,it information of plasticizers No. 41-5 at, college placement
fatty material'' and lodges in generally, this informat'on is offices, federal job informs-
some future president tie- it.
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a distributed within a numhrr jtion centers or from CSC hers of individual regulations . , . at 1900 K St. nw.
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ed in tin- Food and Drug `u'| inary FDA research, the;
ministration.
[agency says, indicates that
FDA recently pondered a re-[ppthalates have no known c-
quest for technical data from;fect on humans and "metabo-i
a Ralph Nader study group ;iize when eaten."
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After a delav ofairmst five;
the m0li,ent FDA EavJ
mon hs, }
mo it was notla number 0[ ppUtions for pln5.
exactly - what_ RaderS;lic coo!dn?.baklI1E bag5 are;
raiders \v, rad. Furtner, FDAstudv, and are not avail-
which would require extensive searching of hundreds of pe titions and many months of effort.
"If you desire extraction/ migration data from all of the above, this would magnify several fold the required ef fort of screening through thp many petitions. We are unable to make an estimate of the time and cost of this magni fied request. It is possible
| Dean TS. Bicrley has retired Trom Housing and Urban De velopment after 43 years of federal service. Bicrley, a com* munieations specialist, spent 20 years with Civil Sort lea Commission and predecessor agencies of Federal Auction Administration.
Language Harrier: U.S. Pos tal Service's employee news paper, Postal Leader, un
said finding out what Narier^ble as public information un
wanted, depending on what itdil FDA issues regulations on was, could take several addi-(thc*n. Manuk cturers of the
tional'months and cost as much'ba3s are a'so leaning on FDA
as $20,000, or more. _ c--iu
jnot t0 felcase chemical nrake-j , , ,, , !up data, because trade sc -ets.
that the cost of your request may range from approximate ly $2/ i for limited information to as high as $20,000 or more,"
Summer .lobs: Civil Service
earthed this ''authentic ex ample of foggy jargon" in a postal publication:
"It is important that post office boxholders are rot giv en the erroneous trere--ion
D . E en K, Si berge d, BaF jwou;^ nQ ionger be Secrc`,s in; Commission has announced that the U.S. Postal Service L*
timore, a Nader research* r,,^ piastjc bag-making trade. 1 three test dates for high school increasing post office box ren
asked FDA for Information on The Oct. 12 letter from FDA and college students who want tals, when post office box
the chemical composition of t0 j)r, snbergeld concluded to work for Uncle Sam next charges are increased pursu
plastic cooking bags used for "If you need to know all summer. Applications received ant to section 169.2, Postal
everything from boiling car- toxicological information on by Nov. 24 will be scheduled Service Manual."
ASI-PR 0001239