Via fax 10/12/2010 09:33 AM

Dear Ms. Cunningham:

 

In a written letter submitted to Assistant Administrator Stephen Owens
late last week, The Procter & Gamble Company acknowledged receipt of
EPA’s request to participate in the voluntary Confidential Business
Information (CBI) Declassification Challenge.  P&G committed to
reviewing our internal files in a good faith effort to identify any
historical CBI claims for which continued protection is no longer
warranted.

 

As we begin the process of searching through our internal TSCA filings
related to inventory status (TSCA Section 5 Notices of Commencement),
TSCA 8(a) Inventory Update Rule reports, and health and safety study
submissions made under TSCA 4, 8(d) and 8(e), we are faced with a
daunting task of sorting through numerous paper files stored in multiple
locations.  Is it possible for EPA to provide P&G with any information
and/or tools that may assist us identify the number and type of chemical
identity CBI claims submitted to the Agency in TSCA filings over the
last three decades?  I am curious if EPA has some sort of “Master
List” of P&G chemical identity CBI claims against which we can
cross-check to sharpen the focus of our internal search and ensure we
review all CBI claims of interest to the Agency.

 

I appreciate any guidance you can provide to better enable P&G to
successfully comply with this voluntary program.  I’m happy to discuss
this request in greater detail, and can be reached at   HYPERLINK
"mailto:froelicher.jm@pg.com"  froelicher.jm@pg.com  or (513) 983-2531.

 

Thank you,

 

Julie Froelicher

US Regulatory Affairs Manager

The Procter & Gamble Company

 

Julie Froelicher  I  NA MDO Regulatory & Technical Relations  I  The
Procter & Gamble Company  I  P: 513.983.2531  I    HYPERLINK
"mailto:froelicher.jm@pg.com"  froelicher.jm@pg.com 

