Message
From: Sent: To: CC:
Subject:
Bromberg, Kevin L. [kevin.bromberg@sba.gov] 4/12/2018 3:03:17 PM Christopher Zarba [________x. 6 _______ j Beck, Nancy [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=168ecb5184ac44de95a913297f353745-Beck, Nancy] RE: Chris Zarba Lunch
Very funny
From: Christopher Zarba [j
Ex. 6
j
Sent: Thursday, April 12, 2018 1i :03 AM
To: Bromberg, Kevin L.
Cc: Beck, Nancy
Subject: Re: Chris Zarba Lunch
You working people are so inflexible. 27th works for me. :-)
Sent from my iPhone
On Apr 12, 2018, at 10:06 AM, Bromberg, Kevin L. <kevin.bromberg(5)sba.gov> wrote:
Next week is out for me. What about Friday April 27?- we can try again.
From: Beck, Nancy \ mailto:Beck.Nancv@epa.qov1 Sent: Wednesday, April 11, 2018 6:53 PM To: Christopher Zarba Cc: Bromberg, Kevin L. Subject: RE: Chris Zarba Lunch
Ok. I have meetings all Friday afternoon so coffee wont work. Chris-1 hope you are enjoying retirement!
Nancy B. Beck, Ph.D., DABT Deputy Assistant Administrator, OCSPP P: 202-564-1273
!
Ex! 6
!
I_____________________________________________________________ I
beck.nancy@epa.gov
From: Christopher Zarbi
Ex. 6
j
Sent: Wednesday, Aprilll," 2018 6:45 PM
To: Beck, Nancy <Beck.Nancv@epa.gov>
Cc: kevin.bromberg@sba.gov
Subject: Re: Chris Zarba Lunch
Sorry I can't make it. My apologies. I am selling a rental property in VA and the only time that everyone can meet is 1:00 pm. I could come by for a afternoon coffee if anyone is around. Next week and tomorrow are wide open if you want to reschedule.
Sent from my iPhone
Sierra Club v. EPA 18cv3472 NDCA
Tier 12
ED 002061 00045970-00001
On Apr 11, 2018, at 6:35 PM, Beck, Nancy <Beck.Nancy@epa.gov> wrote: Elephant and castle works for me.
Nancy B. Beck, Ph.D., DABT Deputy Assistant Administrator, OCSPP
-P:-2-0-2--5-6-4--1-27-3-- ,
_____Ex. 6_____ ! beck.nancy@epa.gov
From: Bromberg, Kevin L. [mailto:kevin.bromberg@sba.gov] Sent: Wednesday, April 11, 2018 5:45 PM To: Beck, Nancy <Beck.Nancy@epa.gov>; Christopher Zarba Subject: RE: Chris Zarba Lunch
Ex. 6
Reconfirming - we should do it: near Nancy - any ideas? Same place as last time?
Kevin
From: Beck, Nancy \ mailto:Beck.Nancy@epa.qov1 Sent: Tuesday, March 20, 2018 7:43 AM To: Christopher Zarba; Bromberg, Kevin L. Subject: RE: Chris Zarba Lunch
Ok. I've penciled in the 13th. Lets see if it sticks!
Nancy B. Beck, Ph.D., DABT Deputy Assistant Administrator, OCSPP P: 202-564-1273
ZZZiZZZZZ
bec.k.nancy@epa.gov
From: Christopher Zarbaj
Ex. 6
Sent: Monday, March li'2D T87 :7 5 `PM
To: kevin.bromberg@sba.gov
Cc: Beck, Nancy <Beck.Nancy@epa.gov>
Subject: Re: Chris Zarba Lunch
I will give you a call tomorrow on the conflicts issue. The 13th works for me. Belize was wonderful. Got buckets of lion fish, had a close encounter with a huge shark, got lots of running in and the weather was perfect.
On Mar 19, 2018, at 4:34 PM, Bromberg, Kevin L. <kevin.bromberg@sba.gov> wrote:
Nancy and Chris : How about Friday April 6 or 13 for lunch? Chris hope you had a nice vacation in Belize.
Chris, I've got a question about conflict of interest and public positions if you don't mind calling me, I'm in office tomorrow (202-205-6964) or
working from home today Ex. 6 See text below.
Sierra Club v. EPA 18cv3472 NDCA
Tier 12
ED 002061 00045970-00002
Hope to see you all soon.
Kevin
From 2015 OIG report https://www.epa.gov/sites/production/files/201509/documents/20130911-13-p-0387.pdf:
Disagreement OIG Recommendation No. 4:
Designated Agency Ethics Official (see Endnote 1) to provide clarification or instruction to Deputy Ethics Officials for assessing whether public statements create an appearance of a lack of impartiality with respect to when the statements were made and the expert's role at the time of the statement.
Agency's Response: Pursuant to 5 CFR 2638.203, the DAEO is responsible for managing the Agency's ethics program, including ensuring that EPA employees adhere to the conflict of interest statutes set forth in Title 18 of the United States Code and to the Standards of Ethical Conduct for Employees of the Executive Branch, 5 CFR Part 2635. The Standards of Ethical Conduct include, at 5 CFR Part 2635, Subpart E, specific provisions for "Impartiality in Performing Official Duties." The OIG recommendation falls outside the purview of federal ethics. These regulations set forth the standard that an employee is responsible, in the first instance, or identifying whether any of his "covered relationships" will cause a reasonable person with knowledge of the relevant facts to question his ability to carry out his official duties with respect to a specific party matter impartially. Typically, the SAB does not deal with "specific party" matters but rather with matters of general applicability. Further, a public statement does not fall within the "covered relationships" set forth at 5 CFR 2635.502, and therefore OGC ethics is not the responsible party overseeing these decisions. From a policy perspective, however, when an individual has made public statements about a matter that will be considered by the advisory panel that may raise a concern about whether the individual has an open mind. The agency's current Peer Review Handbook recommends that staff avoid selecting people for a peer review if they have publicly expressed an opinion on the matter to be considered by the peer review The Handbook also acknowledges the challenge of selecting advisory committee members who have the requisite experience or technical expertise and who have not made public statements. For this reason, the Handbook allows EPA the discretion to decide to include members who have made public statements.
Kevin
From: Beck, Nancy fmailto:Beck.Nancv@epa.qov1 Sent: Friday, February 02, 2018 10:41 AM To: Bromberg, Kevin L.; Zarba, Christopher Subject: RE: Chris Zarba Lunch
Sierra Club v. EPA 18cv3472 NDCA
Tier 12
ED 002061 00045970-00003
Always happy to join if I can make it work. Fridays are best for me. I'm presuming it will have to be after Chris' fabulous Belize trip.
IRIS not so interesting to me--gotta keep my focus on TSCA, but I would come for the company. Nancy
Nancy B. Beck, Ph.D., DABT Deputy Assistant Administrator, OCSPP P: 202-564-1273
ZZZZ1Z.Z.ZZZ]
bec.k.nancy@epa.gov
From: Bromberg, Kevin L. [mailto:kevin.bromberg@sba.gov1 Sent: Friday, February 2, 2018 10:31 AM To: Zarba, Christopher <Zarba.Christopher@epa.gov> Cc: Beck, Nancy <Beck.Nancy@epa.gov>; chriszarba@yahoo.com Subject: Chris Zarba Lunch
Ex. 6
Nancy - I would love in a few weeks to have lunch with you and Chris to discuss IRIS and other issues.. I know you just had lunch with Chris but I know it would be fun for us to get together again.
Next week, I'll try to suggest some dates if you'll agree - otherwise I'll just meet with Chris.
Best, Kevin
CimageOO1,png> Kevin Bromberg
Assistant Chief Counsel for Environmental Policy <image002.png> SBA // Office of Advocacy
409 3rd St. SW, Washington, D.C. 20416 <image003.png> kevin.bromberg@sba.gov <image004.png> 202.48 1.2963 <image005.png> 202.205.6964
<image006.png> <image007.png><image008.png><image009.pngxi
mage010.png> <mage011.pngximage012.pngximage013.pn
g>
Sierra Club v. EPA 18cv3472 NDCA
Tier 12
ED 002061 00045970-00004
Sierra Club v. EPA 18cv3472 NDCA
Tier 12
ED 002061 00045970-00005