Document qqE8omGnLGpjnLD67rQ772nG

Message From: Sent: To: CC: Subject: Attachments: Dr. William Irwin, DABT, ERTj Ex. 6 Personal Privacy (PP) i 12/15/2017 3:33:08 AM 1 ' Beck, Nancy [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=168ecb5184ac44de95a913297f353745-Beck, Nancy] Irwin, William [/o=ExchangeLabs/ou=Exchange Adm inistrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=42ee3c23dl90402e8d315f22ba39e4e8-lrwin, William] "Defined Formats" Proposal Defined Formats Proposal_Wlrwin Comments Accepted.pdf Flag: Flag fo r follow up Hi Nancy, I am attachi ng a money-saving proposal for OPP for your consideration, which was written by D r . John Doherty, DABT and myself. I have supported D r . Doherty on thi s proposal si nee 2011. John was furious at al1 the hysteri a menti oned in the NYT arti cle and in the newspapers on chiorpyri fo s, hi s project for years. John is an excel 1ent toxi cologist with 40 years of experience, one of the very best from OPP. Our honest intent for the proposal was based on that it was the duty of al1 federal employees to increase efficiencies and to save the taxpayers money. John was shocked that he was faced with intimidation in HED on thi s id e a , even though it would save OPP $ mi 11io n s . He has recently become convi need that there is a confli ct of interest by those whom ori gi nated from CROs to support the id e a . John recently made a comment that he was considering sending the proposal to the IG forconsideration. I d o n 't know whether he was joki ng or no t.I ca n't control John's acti o n s . But to be fai r to y o u , I thought that you should be sent our proposal in case he does. Al1 that Ican say is that the pharma industry from where I ori gi nated is far more effi ci ent than the pesti ci des offi ce and our ideas wouldhave increased productivity in OPP. I hope that al1 is well there. Thank you for your ti me and consi derati o n . Cheers, D r . Wi 11iam Irwin, DABT, ERT Toxicologist Executive Summary Thi s proposal defi nes a system to improve effi ci ency and to reduce taxpayer costs in the revi ew of the toxi ci t y , chemi stry, fate and exposure studi es submi tted in support of the regi strati on of pesti ci des to the Offi ce of Pesti ci de Programs of the Envi ronmental Protecti on Agency. Thi s Defi ned Formats approach can save OPP $ mi 11ions/year in staff and contract work expenses derived from the taxpayers. Si nee the format was first proposed in the mid 1990's , OPP could have saved over $50 mi 11ion in contract and staff expenses across al1 the di sci pii n e s . The Defi ned Formats system simply al1ows the pesti ci de companies to wri te the pesti ci de draft study analysi s from the full study reports whi ch are then revi ewed by the EPA, savi ng taxpayer money and greatly speedi ng up the regi strati on process. The pesti ci de companies are the experts on the study results and it would be much more effi ci ent if they wrote the evaluati on analysi s and the EPA simply revi ewed the evaluati ons for accuracy. The Defi ned Formats would better al 1ow the EPA to meet the deadli nes and obii gati ons of FIFRA, FQPA and PRIA, for increased protecti on of chi 1dren at decreased cost to the taxpayers. The Defi ned Formats approach to company data eval uati on has appl icati ons in other offices across the Agency for further savi ngs to the taxpayers. The computer technology to support thi s proposal has been avai1able for decades. Sierra Club v. EPA 18cv3472 NDCA Tier 12 ED 002061 00039081-00001