Document p2Zk1LXD0QQ3a0yyv5LQqG7DE
Cosmed conducts ethylene oxide sterilization operations at the facilities identified above and is a member of the Ethylene Oxide Sterilization Association (EOSA). As explained further in the attached letter submitted to EPA on March 17, 2025 on behalf of the EOSA, the technology necessary to implement the standards set forth in the Sterilizer Rule is not available because manufacturers cannot guarantee that existing emissions control equipment will enable sources to meet the new standards, there is not a sufficient supply of the necessary technology, and there are not enough experienced installation professionals and technical experts to install and test that equipment within the compliance timeframes specified in the Sterilizer Rule.
As also explained further in EOSA's March 17, 2025 letter, it is in the national security interests of the United States to issue the requested exemption because if some facilities choose to cease operations rather than attempt compliance (which seems likely), that will disrupt the supply of sterilized medical devices, raise the cost of those devices, and/or force medical suppliers or providers to source sterilized medical devices from abroad.
Please do not hesitate to contact us if additional information is needed. Cosmed appreciates EPA's attention to this important matter and urges EPA to recommend that the President issue the requested exemption as quickly as possible.
Cosmed Group, Inc. Debtor in Possession
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Sierra Club FOIA 2025-EPA-04883
ED_018388_00005675-00002
SC_EVERSPLIT0005463
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AirAction [/O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=FA78B98923384078995E04A73D258D83-AIRACTION] 4/1/2025 9:01:13 PM Jenny, Tracy (TF) [tracy.jenny@us.sasol.com] CORRECTION: Updated email address for CBI related to the Presidential Exemption
In the previous email, an incorrect email address was provided for the submission of electronic Confidential Business Information (CBI). The email address should be:
OAQPS CBIAepa.gov
Thank you.
From: AirAction Sent: Tuesday, April 1, 2025 11:12 AM To: Jenny, Tracy (TF) <tracy.jenny@us.sasol.com> Subject: RE: Presidential Exemption Request - CAA 112(i)(4) - Sasol Chemicals (USA) LLC Westlake, LA Facility
Thank you for emailing the AirAction mailbox to request a Presidential Exemption under section 112(i)(4) of the Clean Air Act and for engaging with EPA in advancing President Trump's Executive Orders and Powering the Great American Comeback. We have received your email and will be in contact soon. If you have Confidential Business Information (CBI) that you'd like to submit, please submit it in electronic version to the 0BI@),epa.go inbox or in hardcopy to:
USEPA, OAQPS CORE CBI Office 4930 Old Page Road Durham, NC 27703
From: Jenny, Tracy (TF) <
Sent: Monday, March 31, 2025 5:53 PM
To: AirAction < Action@epa.gov>
Cc: Jack, Rusty (RI) <rusty.jack@us.sasol.cor-->; Duhon, Glenn (GD) <Glenn.Duhon@us.sasol.com>; Kress, Heather (HN)
<heather.kress@us.sasol.com>; Szabo, Aaron <Szabo.Aaron@epa.gov>; Tardif, Abigale (Abbie)
<Tardif.Abigale@epa.gov>; Donahue, Sean < 'onahue.sean@epa.gov>; Dominguez, Alexander
<dominguez.alexander@epa.gnv>; Tsirigotis, Peter <Tsirigotis.Peter@epa., >; Lassiter, Penny
<Lassiter.Penny@epa.gov>; Lessard, Patrick <,assard.Patrick@epa.gov>; Bouchard, Andrew
<P
.d."
fT,
Subject: Presidential Exemption Request - CAA 112(i)(4) - Sasol Chemicals (USA) LLC Westlake, LA Facility
I Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Please find the attached Subject letter for your review and consideration.
Best Regards, Tracy
Sierra Club FOIA 2025-EPA-04883
ED_018388_00005677-00001
SC_EVERSPLIT0005464