The North American Metal Packaging Alliance

 


October 23, 2009
Volume 2, Issue 4

 

 

About NAMPA

The North American Metal Packaging Alliance, Inc. (NAMPA) is committed to promoting sound science in risk-based decision-making pertinent to the light metal packaging industry, advocating on behalf of the light metal packaging industry on issues pertinent to packaging technologies, and providing customers with needed information regarding light metal packaging technologies and the regulatory frameworks in which these technologies are assessed.

John M. Rost, Ph.D.
Chairman

Want to join NAMPA?

If you would like to support our efforts and play an active role in NAMPA, please consider joining as a full member. Please contact NAMPA at 866-522-0950 or info@metal-pack.org for details.

 

 

NAMPA News


 

 

 

COMMUNICATION ISSUES

 

Introducing NAMPA’s “How To…” Series

 

We need metal packaging stakeholders to become more engaged in the media and the public discourse on bisphenol A (BPA) and its use in epoxy resins in metal packaging.  In an effort to enable interested parties to join these discussions, we have started a new series of “How To” articles in the newsletter.  The article below, “How to Write a Letter to the Editor,” is intended to guide efforts to respond to inaccurate or incomplete articles in local papers.  Other similar articles will follow in future issues of NAMPA News providing practical advice on how to schedule a meeting with a legislator, how to write a letter to Congress, and other topics of interest as offered by our members.

 

How to Write a Letter to the Editor

 

Letters to the editor are an excellent way to become more engaged, as it is one of the most notable forms available to correct the record, challenge asserted facts, and obtain free and effective publicity. Not to mention, these letters are published in the most respected sections of any newspaper, the editorial section.  Writing a thoughtful letter to the editor can influence previously held perceptions of readers, generate expanded coverage of an issue, and impact public policy and legislation.

 

Tips to get your letter to the editor published:

 

  • First and foremost, be prompt! In responding to an article, make sure you respond within two to three days to ensure timeliness.  As a general rule, same day responses have the greatest chance of being printed.

 

  • Be sure to include your name, physical address, e-mail address, and telephone number at the top of your letter. Editors often require this information to verify your identity.

 

  • Limit your letter to two or three paragraphs, max (150-200 words).  Try using this concise format:

 

o       First paragraph -- State your main point and explain why the issue is important to you.  What impact does the issue have on the local community? Are you personally invested in the particular policy or piece of legislation? 

 

o       Second paragraph -- Include facts, quotes, and numbers to support your point.

 

o       Conclusion -- End with a great summary, recommendation, and a clever, punchy line.

 

  • It is very important to state exactly which article you are responding to in the beginning of your letter, including the date of its publication.

 

  • If you have credentials, mention them.  If you have earned a degree or done research in a relevant field, you will be perceived as more credible than someone who has not.

 

  • Using facts, figures, and expert testimony helps bolster your case.

 

  • Do not appear overly emotional.  You can avoid this by limiting your use of exclamation points and always refraining from using insulting language or disparaging individuals or institutions.

 

  • Proofread! Proofread! Proofread!  In addition to correct grammar, spelling, and punctuation, make sure your arguments would make sense to someone without a special background on the issue.

 

  • Make sure you read the instructions on how to submit your letter to the editor specific to the publication you are targeting. Most publications accept e-mail submissions, but prefer the e-mail to be the text of the letter.   Attachments will often get your e-mail deleted by the spam filter.  Some publications have an online form they require to use instead of e-mail, so check the website of the publication and follow the instructions, which are usually found in the Opinion tab of the website.

 

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Putting ppb into Perspective

 

When it comes to talking about potential exposure levels of BPA in metal packaging, the term “parts per billion” (or ppb) is one that is used most often as the key measurement.  Simply put, one part per billion is one drop out of a billion drops.  While this explanation may seem simple enough for those with some scientific training, the “parts per billion” measurement can be very confusing to customers, consumers, and other stakeholders who struggle to make sense of ppb and understand what the term really means for them.  It can also be exceedingly difficult for industry representatives to explain in a way that is easily understood and meaningful to those outside the scientific arena.

 

In the interest of helping NAMPA members and others put this term into proper perspective and to enable them to communicate more effectively with people about potential BPA exposure, we have compiled a list of examples.  Included on this list are several ways to think about “parts per billion” using more common comparisons that provide some perspective on just how miniscule potential levels of exposure are from metal packaging made with BPA epoxy resin liners.

 

So what does parts per billion really mean?  One part per billion is the equivalent of:

 

  • A single raindrop in 250 oil drums filled with water; 

 

  • A single step in a billion steps around the world (equaling 7.5 circles around the globe);

 

  • One single penny of a lottery winner’s $10 million dollar prize;

 

  • One second of time in 31.7 years;

 

  • A pinch of salt in ten tons of potato chips;

 

  • One drop of ink in one of the largest tanker trucks used to haul gasoline; and

 

  • One sheet in a roll of toilet paper stretching from New York to London.

 

So the next time you are asked to explain what parts per billion means for the average person, consider using one of the examples above to offer some perspective and clarity on this important aspect of the debate over BPA.

 

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Questions and Answers about Parts Per Billion from the Scientific Perspective

 

Q:  Which is larger, one part per million (ppm) or one part-per-billion (ppb)?

 

A:  One part per million is a larger quantity than a part-per-billion.  It is important to remember that the larger the base amount (i.e., billion, trillion), the smaller a single part is, since it represents a fraction of a larger whole.  Just as 1/4 is larger than 1/16, one ppm is greater than one ppb.

 

Q:  How does this relate to the other measurements I see associated with exposure to BPA in metal packaging, such as mg/kg or μg/kg or ng/kg?

 

A:  There is a difference in how measurements are applied to liquids versus solids.  One part per million of a solid substance is equivalent to 1 milligram/kilogram (mg/kg); one part per billion is equivalent to 1 microgram/kilogram (μg/kg).  A nanogram per kilogram (ng/kg) is an even smaller notation and relates to one part per trillion.

 

Understanding key measurement terms:

 

  • ppm:  Parts per million. Also mg/L or milligrams per liter
  • ppb:  Parts per billion.  Also μg/L or micrograms per liter.
  • ppt:  Parts per trillion.  Also ng/L or nanograms per liter.
  • mg/kg:  A milligram is one thousandth of a gram.
  • μg/kg:  A microgram is one millionth of a gram.
  • ng/kg:  A nanogram is one billionth of a gram.

 

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Navigating the NAMPA Website

 

One of NAMPA’s key objectives is to provide stakeholders with needed information regarding metal packaging technologies.  As part of that effort, NAMPA maintains a website with important updates on regulatory decisions, informational materials and other relevant information at www.metal-pack.org.  On our home page, we highlight recent news items, such as Germany’s October 2009 conclusion that BPA use in baby bottles is safe.  We also provide links to articles, press releases, or government agency sites.

 

Beyond the current events highlights, the website also provides NAMPA newsletter readers with access to past issues of NAMPA News.  We have developed a library of communication materials that NAMPA News readers are encouraged to use with their customers or other stakeholders.  The “Library” page includes an overview of government agency findings on BPA, a summary of the benefits afforded by metal packaging materials, an explanation of various types of scientific research, and more.  NAMPA continues to develop new materials for this site.

 

If you have not already bookmarked www.metal-pack.org as a favorite, you should do so.  And you should plan to visit the site on a regular basis as we update it with information often. 


 

 

 

FEDERAL ISSUES

 

Schedule for FDA Evaluation of BPA

 

As noted in the previous edition of NAMPA News, the U.S. Food and Drug Administration (FDA) is currently re-evaluating the safety of BPA in food contact applications.  The FDA Center for Food Safety and Applied Nutrition (CFSAN) has been deeply engaged in responding to the FDA Science Board’s criticisms regarding the previous assessment.  In particular, CFSAN has clearly identified criteria for assessing how studies -- including low dose studies -- should be considered in a risk assessment.  Science staff then completed a toxicology review of BPA, using the criteria noted.  That draft review will be considered by a non-FDA government review group of undisclosed identity.  In response to inquiries from NAMPA, Dr. Jesse Goodman, FDA Chief Scientist, stressed that the peer review group was not providing assessment advice, was merely commenting on the toxicology review, and that FDA will consider how best to respond to requests for the identity of the peer reviewers.

 

The non-FDA peer review group will submit its feedback on the toxicology review and criteria on study evaluation back to CFSAN, which will consider them as it develops the final assessment, which is expected to be issued by November 30, 2009.  After the November 30 assessment is issued, FDA will then consider what actions, if any, are needed.  Regardless of the assessment decision, FDA has indicated its intent to be transparent in how/why decisions were reached.

 

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EPA Highlights BPA As Candidate Chemical for Risk Management

 

At the end of September, U.S. Environmental Protection Agency (EPA) Administrator Lisa Jackson spoke on the need for reform of the existing chemical management system, the Toxic Substances Control Act (TSCA), in the United States.  In those remarks, Ms. Jackson highlighted EPA’s intent to focus risk management efforts on several chemicals of concern, including BPA.  The efforts will include development of a “chemical action plan,” which will be based on the EPA’s review of available hazard, exposure, and use information.  The action plan will outline the potential risks that each chemical may present and what specific steps EPA will take to address those concerns.  EPA intends to utilize the regulatory tools under TSCA to address risks, including authority to label, restrict, or ban chemicals under TSCA Section 6.  EPA anticipates completing and posting an initial set of four action plans in December 2009 and will complete and post additional chemical action plans at four-month intervals. More information on EPA’s chemical action plan effort can be found at http://www.epa.gov/oppt/existingchemicals/pubs/ecactionpln.html.


INTERNATIONAL ISSUES

 

WHO Melamine

 

The World Health Organization (WHO) Codex Alimentarius Commission recently announced a work project to establish maximum levels of melamine in food and feed.  WHO suggests that setting maximum limits of melamine will help governments differentiate between unavoidable melamine occurrence and the deliberate adulteration of food and feed.  For more information, see http://www.who.int/mediacentre/news/releases/2009/food_standards_20090706/en/index.html.

 

 

NAMPA WEBSITE

This publication is for informational purposes only and does not contain legal advice. The information presented herein should not be used or relied upon with regard to any particular set of facts without first consulting a lawyer.

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North American Metal Packaging Alliance, Inc. • 1203 19th Street NW, Suite 300 • Washington, DC 20036-2401 • 866-522-0950