I emphasize Dr. Emerson's suggestion that so much food is prepared in restaurants that in your consideration of the size of the container you do take that into consideration. I am deeply grateful to every one of the witnesses, and I think we have gotten so much from the canners and from the producers that is going to be valuable through the years to come, because we are going to have to do many of these things as we go on into a deeper civilization, and the fact is that we do need to protect the health in every conceivable way and we do need the cooperation of every group involved. Thank you very much, Mr. Chairman, for permitting me to make these little comments for your consideration. Mr. HALE. Thank you, Mrs. Bolton. Is Dr. E. M. Nelson of the Food and Drug Administration here? Mr. HALE. Is there anything else that you wish to say? Dr. NELSON. I have nothing to say in addition to what has been said. I recognize the purpose of this measure as being one that is very desirable, and I think Mr. Crawford has pointed out the matters in which the Food and Drug Administration is particularly interested, and in having it clarified so that it can be readily administered. We are in favor of this type of legislation. Mr. HALE. Is there anyone else who wishes to be heard? . If not, I will declare the hearing closed. (Whereupon, at 1: 15 p. m., the hearing was adjourned.) (The following statements and communications were received later to be included in the record.) STATEMENT OF THE COUNCIL ON FOODS AND NUTRITION, AMERICAN MEDICAL ASSOCIATION, CHICAGO, ILL. IODIZED SALT AND GOITER, AND IODINE DEFICIENCY DISEASE The opinion of the council on foods and nutrition of the American Medical Association has been expressed in their booklet, General Decisions on Foods and Food Advertising, July 1946, pages 50 and 51 as follows: "Iodine is an essential chemical element for normal nutrition. Food and drink may inadequately supply this element and consequently an iodine-deficiency disease-simple goiter-may develop. The prevention of goiter is conceived to be largely a nutritional problem depending upon the regular addition of a definite small quantity of an iodine compound or an adequate quantity of an iodine-rich food, to the diet inadequate in this element. A favorable practical method for dispensing the necessary additional food iodine to the public to supplement that naturally present in foods and drink is the fortification of table salt with a definite quantity of a suitable iodine compound. "Although supplemental iodine supplied through salt or other special foods may prevent goiter that would otherwise occur or cure incipient cases, the simple administration of iodine in this manner is not a 'cure all.' The prevention of goiter is a matter of normal nutrition; the cure of goiter is a medical problem. All persons with goiter should be under efficient medical supervision. "An accepted iodized salt shall contain not more than 1 part sodium iodide or the iodine equivalent of any other suitable iodine compound per 5,000 parts salt (approximately 160 parts iodine per million parts salt). Iodized salt containing more than this quantity is considered a medicament not to be advertised to the public for table and cooking uses. "Salt containing as little as 1 part sodium iodide or the iodine equivalent of any other suitable iodine compound per 10,000 parts of salt shall be acceptable to the council provided the salt uniformly contains this much iodine when manufactured, contains this much iodine after standing under ordinary conditions of storage and otherwise complies with the rules of the council." At the May 23, 1947, meeting of the council on foods and nutrition, H. R. 2717 (the Bolton bill) was discussed. The consensus of opinion as expressed at the meeting was as follows: 1. The amount of iodine proposed by H. R. 2717 is stated as "suitable iodides in qauntity equivalent to not less than 80 and not more than 160 parts per million of such salt." It was the consensus of opinion of the council that 75 to 150 parts per million would be satisfactory from a public-health standpoint if there were technical reasons for such a suggestion. 2. With reference to the date of enactment, the council felt that since iodized salt is now available for those who choose it and since the public-health aspect of this problem is not an emergency that it would be well to extend the date of enforcement to 1 year from the date of adoption. 3. As used by the council the word "table salt" is intended to mean salt ordinarily used in homes or restaurants on the table or in the kitchen for the seasoning of food at the time of preparation for the meal or by the individual at the table and in amounts that would never exceed that required in usual kitchen (home or restaurant) recipes. The council is opposed to the use of iodized salt in manufactured or processed or canned foods until such a time as evidence is presented that such is a required and a safe technical procedure. Pure NaCl should be available for home canning when recipes specifically call for pure NaCl in preference to iodized salt and for individuals for whom it is recommended by recognized medical authority. WASHINGTON 6, D. C., June 30, 1947. Re H. R. 2717. Hon. ROBERT HALE, House Office Building, Washington, D. C. DEAR MR. CONGRESSMAN: With reference to the letter from Dr. John H. Stokęs expressing his views on the proposed H. R. 2717, I am setting forth here a brief history of this gentleman's activities in the field of dermatology: "Professor of dermatology and syphilology in the school of medicine, University of Pennsylvania; professor in the graduate school of medicine, University of Pennsylvania; formerly head of the section on dermatology and syphilology, the Mayo Clinic, Rochester, Minn.; formerly professor of dermatology and syphilology in the graduate school of medicine, University of Minnesota." With all good wishes, Sincerely yours, A. D. CONDON. PHILADELPHIA 4, PA., June 26, 1947. Mr. ARTHUR D. CONDON, Suydum and Condon, Attorneys at Law, Washington 6, D. C. DEAR MR. CONDON: Replying to your letter of June 23, with regard to H. R. 2717, requiring that all table salt be iodized, I express the following personal views with regard to this matter. There would appear to me to be no peremptory necessity for subjecting all salt consumed by the public to an iodine supplement. The purpose of iodine supplements in general in table salt is to make good deficiencies which occur in the iodine content of food in parts of the country far removed from the seacoast and long out of the ocean, so to speak. I can understand therefore, why a more or less routine use of iodized salt might be suggested in the Middle West, but I can see relatively little occasion, if any, for such universal use of iodized salt along the coastal areas, which include a large part of this country. I would direct attention also to certain deleterious effects of iodinization which are now quite commonly considered to exist, particularly in the field of dermatology which is my specialty. It is well known that the disease, dermatitis herpetiformis, is made markedly worse by the administration of even very minute amounts of potassium or sodium iodide, and iodized salt is routinely excluded from the diets of such persons in the hope of benefitting them. It has also for some time been considered that iodine, which is well known to produce in susceptible individuals, eruptive manifestations of pustular type, is undesirable at least in the form of added supplement in the diet of persons with acne vulgaris and pustular eruptions of various types. A number of observers in this country have subscribed to this view, particularly in the New York group, and it is now a routine point of inquiry in taking the histories of acne patients, and a more or less routine exclusion of iodized salt is prescribed. Acne is an extremely common disease, especially in younger persons, and the volume of individuals affected by what amounts to a forced ingestion of supplementary iodine might be very large. Speaking to the point of the general status of medical lawmaking of this sort, I may say that legislation to force all sodium chloride for table use to be supplemented by potassium iodide appeals to me as one of the worst types of medical crankism. As long as iodized salt is available in unlimited quantities to all who desire it, and uniodized salt likewise, it seems to me that the problem is one of education and not of legislation. As the matter stands at the present time, it has been shown, I believe by a special inquiry, that the individual who purchases salt at a grocery, if he asks for nothing but salt, gets iodized salt three times out of five. If such is the case, he certainly need not suffer from an iodine deficiency that can be supplemented in table salt, and there is no reason to force his neighbor to take iodine in this fashion unless it is deemed advisable that he do so from the medical standpoint. There are innumerable agents, including drugs, that, if this type of legislation once gains headway, might be added to foods in a plan of forced therapy that would be wholly unjustified. I would like to protest, then, the passage of such a bill as H. R. 2717 as contrary to a wise public policy, medical expediency, and the medical facts above cited. JOHN H. STOKES, M. D. STATEMENT OF DR. BROCK E. BRUSH, HENRY FORD HOSPITAL, DETROIT, MICH. Our part in this program has been the study of the reduction in goiter operations brought about by the use of iodized salt in Michigan. Dr. Roy D. McClure, surgeon in chief of the Henry Ford Hospital in Detroit, and I have conducted surveys of the number of goiter operations and the total number of operations performed in seven hospitals throughout the State of Michigan. These surveys begun in 1928 by Dr. McClure, 4 years after the introduction of iodized salt in Michigan and continuing through 1944, have shown conclusively that there has been a steady reduction in the number of people requiring thyroid operations. The total number of operations performed in these hospitals has continued to increase year after year, while the number of thyroid operations has decreased steadily. We know that iodine lack causes endemic goiter which we believe may later on change to other pathological states in the thyroid gland, requiring an operation, Since we have seen these marked beneficial effects from the use of iodized salt, we are in strong support of this proposed legislation to have all table salt iodized. CONGRESS OF THE UNITED STATES, HOUSE OF REPRESENTATIVES, Hon. ROBERT HALE, Member of Congress, House of Representatives, Washington 25, D. C. MY DEAR MR. HALE: I understand that a subcommittee, of which you are chairman, of the Interstate and Foreign Commerce Committee is considering H. R. 2717, a bill to propose that salt producers shall sell no table salt except that treated with potassium iodide. I believe that this bill would establish a dangerous precedent. If our people are to be denied by law the use of pure table salt and compelled to use only table salt with iodine added, what is to prevent the enactment of similar harmful legislation affecting other food products? For many years salt producers throughout the country have made iodized salt available to all who want or need it. Thus the housewife has been free to choose either pure or iodized table salt. We in Louisiana, and that applies also to other coastal regions, do not require iodized salt, because of the presence of iodine in seafoods and other natural foods of the region. On the other hand, it is a proved fact that an excess of iodine is positively harmful to some people. As one illustration, about the first thing a dermatologist asks when consulted about acne or other skin eruptions is whether or not the patient has used salt containing iodine, that being generally regarded as a stimulant to the sebaceous glands and a possible cause of skin eruptions. While the medical profession in the Great Lakes region, where goiter is prevalent, strongly advocates the use of iodized salt, there is a widespread opinion among doctors in other sections of the country that it would be unwise to enforce the use of iodized salt among people who have given no evidence of individual need of it, especially since iodized salt has been and will continue to be available in all parts of the country to all who need or want it. Iodine is medication; it is the function of the physician to prescribe it for the individual in need of it. I strongly feel that medication should not be forced upon the public by Government regulations. Louisiana is one of the largest salt-producing areas in the country. If it is in order I would appreciate your filing this protest in the hearings before your committee. I will appreciate your kind consideration and that of your committee. With every good wish and kindest regards, I am Sincerely yours, Mr. ALFONS B. LANDA, Washington, D. C. JAMES DOMENGEAUX. NEW YORK, July 8, 1947. DEAR MR. LANDA: Reference your letter of July 1, instead of making all table salt iodized, it is strongly advisable for the Government to insist on legislation in order to make all salt, for general table use, not to be iodized as there are hundreds, possibly thousands, of persons in whom skin rashes have been caused or aggravated by the ingestion of iodized salt. There is also another danger, and that is that a patient may become sensitized to iodine by such ingestion, and it may result in a fatal ending as indicated in the enclosed reprint. Sincerely yours, (Enclosure filed with committee.) JOSEPH J. ELLER, M. D. STATEMENT OF JAMES H. WINSTON, OF MILLER, GORHAM, WESCOTT & ADAMS, 1 La SALLE STREET, CHICAGO, ILL. Congress should be reluctant to pass any more sumptuary laws. The prohibition statute, for example, undertook to regulate what people should drink or rather what they should not drink. And it proved to be unpopular enough. But it undertook only to prohibit. It did not, as does this bill, affirmatively require people to take anything. In practical effect, this bill would not only prohibit the use of what we ordinarily called "salt," but in addition, it would compel people to take an added drug in order to get their daily salt at all. In the final analysis, the avowed intention of the proponents of this bill comes to this: There are some people left in the goiter belt who need iodized salt, a product which is already available to them, and we have tried to educate them to take it, but as long as it continues to be labeled iodized salt, and ordinary salt is obtainable, they are so stubborn that they refuse to buy iodized salt. So, in order to fool those people into taking iodized salt, we are going to have the Congress of the United States pass a law which will outlaw ordinary table salt, which will require all table salt to be iodized and nevertheless to be labeled merely "salt." That is to be be done without regard to the health of millions of other people who admittedly don't need any more iodine, and without regard to the health of thousands of people who are allergic to iodine and therefore can't take it even in the smallest quantity. As heretofore stated, we, as salt producers, have no selfish or personal interest in opposing this bill. We are opposing it because as citizens we think it is improvident legislation, for the reasons which we have stated. But since opposition coming from private interests is suspect and operates to the prejudice of the public interest which is at stake, we have decided to retire from carrying the banner. However, we caution the committee, and wish you to know that we are desirous of assisting the committee in its sober deliberation on a bill which we believe so vitally concerns the health of everybody. After all, we do have a legitimate interest in the matter, because it is our product which will be the innocent victim of the confusion and public disapproval which will be incident to the enactment of this bill. It is not as if our product were unwholesome or deleterious, or as if iodine had been extracted from our product. A moment's reflection will bring home to you the fact that our product, rather than sugar or some other food, is being selected as the medium for carrying iodine, simply because everybody has to eat salt. The bill H. R. 4211 was introduced following the hearing on H. R. 2717 and is made a part of the record at this point, along with reports received under the departments and other material submitted to the subcommittee on H. R. 4211. [H. R. 4211, 80th Cong., 1st sess.] A BILL To amend section 301 of the Federal Food, Drug, and Cosmetic Act, so as to prohibit the introduction into interstate commerce of salt, in certain containers, not having a required content of iodides Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, That paragraph (a) of section 301 of the Federal Food, Drug, and Cosmetic Act, as amended (U. S. C., 1940 edition, title 21, sec. 331), is hereby amended by inserting "(1)" after "interstate commerce" and by striking out the period at the end of such paragraph and inserting a comma and the following: "or (2) of salt (sodium chloride) sold or to be sold in containers containing three pounds or less of salt, the granules of which will pass through a number 20 United States standard sieve, unless such salt contains suitable iodides in a quantity equivalent to not less than seventy-five parts and not more than one hundred and fifty parts of iodine per million parts of such salt." SEC. 2. The amendment made by this Act shall take effect one year after the date of the enactment of this Act. Hon. CHARLES A. WOLVERTON, THE SECRETARY OF COMMERCE, Washington 25, September 17, 1947. Chairman, Committee on Interstate and Foreign Commerce, House of Representatives, Washington, D. C. DEAR MR. CHAIRMAN: This letter is in further response to your communication of July 16, 1947, request this department for its views concerning H. R. 4211, a bill "To amend section 301 of the Federal Food, Drug, and Cosmetic Act, so as to prohibit the introduction into interstate commerce of salt, in certain containers, not having a required content of iodides. This bill provides for the inclusion of suitable quantities of iodides in containers of salt, three pounds or less, presumably in an attempt to control the problem of endemic goiter which exists in widespread areas throughout the country. The essential issue presented by this bill is whether the national health factors involved (concerning which we are unqualified to speak) outweigh such arguments as might be advanced against imposing this additional Government control on salt manufacturers and those who deal in table salt. Although it appears reasonable from the standpoint of the manufacturer to limit the iodide requirement to three-pound containers or less, and therefore to sales of salt for table and culinary use, and although we are informed that iodized salt now on the market does not cost any more at wholesale or retail than noniodized salt, this department does not have readily available any technical data as to the true nature of the burden, if any, which would be imposed on the salt manufacturer as a result of enactment of this legislation. Accordingly, while we have no objection to the legislation, we have no basis for affirmatively recommending its enactment. We regret that we are unable to be more helpful in this matter. DAVID BRUCE, Acting Secretary of Commerce. FEDERAL SECURITY AGENCY, Hon. CHARLES A. WOLVERTON, Chairman, Committee on Interstate and Foreign Commerce DEAR MR. CHAIRMAN: This letter is in response to your request of July 16, 1947, for a report on H. R. 4211, a bill to amend section 301 of the Federal Food, Drug, and Cosmetic Act, so as to prohibit the introduction into interstate commerce of salt, in certain containers, not having a required content of iodides. |