law

offices

Keller alsjd Heckman
• JOSEPH r.

KELLER

JEROME H

HECKMAV

CHARLES M, MEEHAN
WILLIAM H

ItlH X STREET. N

W

'V

WASHINGTON, D.C. U0036

TELEPHONE

BOROHRhAN

soa

ROBERT R TIERNAN

ao&-aToo

CABLE ALBSESS "KEI.MAX"

WAYSE V. BLACK
DAVID L HILL
MARTIN W BERCOVICI

February 10,

MARC R sHAYE

TO:

1971

All Members of the SPI Food, Drug
and Cosmetic Packaging Materials
Committee.

Gentlemen:
Following up on our February 5 letter
as it related, in the last portion, to our efforts
on behalf of the Inter-Industry Committee to
bring about some action on the so-called "Ramsey
proposal," this is to advise you that we have now
spoken with Tom Brown and General Delmore about
the situation.
In so doing, we left little doubt
about our disappointment with the results of the
meeting we had with Messrs. Ramsey, McLaughlin,
Holts and Buckley on February 3.
Without even attempting to recap
some of the interchange in the discussion we had
with Mr. Brown--this being virtually impossible
to do effectively here—we simply want you to
know that, on the strength of his recommendation,
we now plan to set about drafting a relatively
formal petition for general rule-making aimed at
presenting FDA with an industry-made platform for
taking action along the lines of previous consid­
eration.
We have reason to believe mat sued a
petition is at least worth trying since we now
have the impression that Mr.- Brown would send it
forward to the Commissioner's Office with a reason­
able stamp of his approval, assuming he agrees
with what we prepare and file.
You should understand that, because
of some of the scheduling congestion I anticipate
in the next two months, and because of the sort
of petition and back-up data Mr, Brown has urged

ASI-PR 0001171

February 10,
Page Two

1971

us to submit, it is likely to be some time
before Jack Frawley, Einar Wulfsberg and I
can develop the type of document to be sent
to you and the Inter-Industry Committee for
approval prior to filing.
Furthermore, some
of the ideas I plan to incorporate in the
draft petition, as long as we seem compelled
to pursue this route, will probably constitute
a bit of a proposed expansion of the Ramsey
concepts.
Thus, we will have to ask. again for
your patience and understanding while we go
about preparing what we have in mind.
We are at least a little more
hopeful about our ultimate prospects now and
trust that this letter will convey this feel­
ing to you.
Any comments, suggestions for
our draft petition, or questions you might
have after you consider the foregoing will be
most welcome.
Cordially yours.

ASI-PR 0001172