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Dr. OLNEY. Well, I share your high regard for the National Academy of Sciences as a whole. However, I am not sure that any individual or any agency is absolutely above reproach, in the sense that we all have shortcomings and room for improvement. Recently questions have been raised even by NAS members about ways in which NRC, the operating arm of NAS, could be improved and one of the areas in which NAS/NRC advisory role has been most criticized has been with respect to its handling of environmental issues-just such issues as we are discussing today. I would like to suggest that the operators of the NRC, and particularly certain of its committees such as the Food Protection Committee, would be a reasonable topic for Senate investigation. If such an investigation were scheduled, I would be happy to testify on problems I have observed, for example, the use of questionable criteria in selecting subcommittee members.

Senator PERCY. Can you give us the composition of the Food Protection Committee and its MSG subcommittee?

MEMBERS APPOINTED TO MSG SUBCOMMITTEE

Dr. OLNEY. I don't have the composition of the Food Protection Committee but I have a list of the members who were appointed to the MSG subcommittee.

Here are the subcommittee members. The chairman was-
Senator PERCY. Can you identify their affiliation?

Dr. OLNEYS The chairman, Dr. Lloyd Filer, whose current title is Mead Johnson professor of pediatrics, University of Iowa, was previously, for 13 years of his professional career, the director of Ross Laboratories before going to Iowa University.

As I mentioned, certain MSG studies conducted by Dr. Filer and colleagues were funded by Gerber Products Inc., and IMC-International Mineral and Chemical Co.-while he was the chairman of the subcommittee. As you may know, IMC was then manufacturing about 85 percent of the MSG consumed in the United States.

You said I made serious charges of collusion and distortion of evidence. I tried, as I introduced this issue, to say that I would prefer to keep the focus off of scientific individuals as much as possible while turning it onto problems in the system; and distortion of evidence is a problem in the system.

It becomes very difficult to be objective when you are appointed as a chairman of a subcommittee and at the same time are receiving moneys supporting your activities from the very industries whose interests are being reviewed.

Dr. Dreyfus is with the University of California in the department of neurology, and he is the single member out of the seven member subcommittee who did have background knowledge in the area of neuropathology. He is the one member of the committee I consider eminently qualified to judge evidence relating to a brain damage syndrome.

He came to my laboratory and examined my evidence very closely. Unfortunately, he did not go to the other laboratories and examine their evidence, and it was their evidence-laboratories A and B-that was used as a basis for all of the subcommittee's conclusions.

Senator PERCY. Would you feel his examination of your evidence was thorough and competent?

FAVORABLE REPORT OF TECHNIQUES AND METHODS

Dr. OLNEY. Yes, sir, I do. I have talked with him, and as I understand it, he submitted a report which was not filed formally as a dissenting report, but a report describing in favorable terms all the techniques and methods employed in my laboratory and a statement that he supported the findings.

However, in the final report of the subcommittee it didn't come across that way. There was greater favor shown to the evidence from laboratories A and B and Dr. Dreyfus informed me that he did not go to their laboratories to examine their data and methods at first hand. Senator PERCY. Do you know if he supported the conclusion of the subcommittee that the sale of MSG in packages for institutional and home consumer use need not be curtailed?

Dr. OLNEY. I don't know, I would have to ask that he be contacted on that.

Senator PERCY. All right.

Dr. OLNEY. Other members of the subcommittee were as follows: Dr. Virgil Robinson is a doctor of veterinary medicine, employed for the past 18 years by Dow Chemical Co.

Dr. John Zapp is a biochemist employed for the past 26 years by Du Pont. Dr. George Owen is a pediatrician affiliated with Children's Hospital in Columbus, Ohio, Dr. Owen has published research within the past 3 years supported by Gerber Products.

Senator PERCY. We will have to recess for a few minutes. I think Senator Nelson will be back, and I will be back right after that. (Whereupon, a brief recess was taken.)

Senator NELSON. The hearings will resume.

Well, I guess I am going to have to let you run, Dr. Olney.

We have a panel of six witnesses representing the Grocery Manufacturers of America. The panel is led by Terrance Hanold, president of the Pillsbury Co.: with him are John Creger, Esq., senior attorney, Krafteo Corp.; Dr. Richard Hall, vice president, research and development, McCormick & Co., Inc.; Dr. Andrew G. Ebert, director of product safety and regulatory affairs, William Underwood Co.; Dr. Lloyd W. Hazleton, adviser and consultant, Hazleton Laboratories, Inc.; and Dr. Paul F. Hopper, director environmental health sciences, General Foods Corp.

Are all you gentlemen present?

Mr. HANOLD. Mr. Chairman and members of the committee:

PANEL FROM GROCERY MANUFACTURERS OF AMERICA, INC., LED BY TERRANCE HANOLD, PRESIDENT OF PILLSBURY CO.

I am Terrance Hanold, president of the Pillsbury Co. I am here today on behalf of the Grocery Manufacturers of America, Inc. (GMA). As a responsive industry we are pleased at your invitation. It is a credit to this committee to seek the views of a broad segment of our society, including the food industry.

This is the third occasion on which GMA member companies have presented testimony before the Senate Select Committee on Nutrition and Human Needs. Previously, testimony was delivered on the role of our industry in matters of nutrition and nutrition education. After

the White House Conference on Food, Nutrition and Health, we were invited back to report on substantive progress by our industry in these

areas.

The Grocery Manufacturers of America is a trade association of the Nation's leading manufacturers of grocery products, which include the major manufacturers of food products in this country. Hence, we welcome this opportunity to comment on S. 76 and S. 3163, both of which propose changes of major impact on our food supply.

FIVE SPECIALISTS

Mr. Chairman, I am accompanied today by five specialists, each of whom will present testimony on an aspect of your request to GMA. Following my testimony on nutritional standard setting and labeling, Mr. John M. Creger, senior attorney with the Kraftco Corp., will comment on regulations which have been issued by the Food and Drug Administration during the last year and a half as they affect the food industry. Mr. Creger graduated from the State University of Iowa College of Law with distinction and served successively as assistant attorney general for the State of Iowa, in the law department of the Pillsbury Co., and currently is senior attorney in the law department of the Kraftco Corp. in charge of the function of food and drug law and environmental law.

Our third witness will be Dr. Richard L. Hall, who is vice president of research and development for McCormick and Co. Dr. Hall received his degree in chemistry from Harvard. He is the immediate past president of the Institute of Food Technologists and a member of the Panel on Chemicals and Health of the President's Science and Advisory Committee. His testimony will deal with the question of food additive efficacy.

The fourth witness will be Dr. Andrew G. Ebert, who is director of product safety and regulatory affairs for the William Underwood Co. Dr. Ebert received his degree in pharmacology from Purdue University. He has had scientific and management responsibilities at the Squibb Institute for Medical Research, International Minerals and Chemicals Corp. and now with the William Underwood Co. His remarks will respond to the question of third-party testing for food additives.

Dr. Lloyd W. Hazleton, our next witness, is the founder of Hazleton Laboratories, an independent testing laboratory with a distinguished record of service to Government and industry. Dr. Hazelton received his Ph. D. in pharmacology from the University of Washington and is currently an adviser and contultant with Hazelton Laboratories. His remarks will be directed to the Delaney amendment.

Our final witness this morning is Dr. Paul F. Hopper, director of environmental health sciences with the General Foods Corp. In this capacity, he has the responsibility for testing the safety of the prod ucts and ingredients being used by General Foods. His Ph. D. in organic chemistry is from the University of Notre Dame. Dr. Hopper was a member of the panel which advised FDA on protocol design for use at the National Center for Toxicological Research. In addition, he is chairman of the GMA Subcommittee which is working in close

cooperation with the Food and Drug Administration and the U.S. Department of Agriculture to pool information on the nutritional composition of food ingredients. Dr. Hopper will present testimony on the National Center for Toxicological Research in Pine Bluff, Ark. Senator NELSON. Do you want the rest of the panel to be at the table with you?

Mr. HANOLD. I will call them to the table.

Mr. Creger, attorney from Kraftco.

Our next man with me will be Dr. Hall, vice president, research and development, for McCormick Co.

Dr. Andrew Ebert, director of product safety for the William Underwood Co.

Dr. Lloyd Hazleton, the founder of Hazleton Laboratories, and a consultant to that institution at this time.

And Dr. Paul F. Hopper, director of environmental health sciences, with General Foods Corp.

Mr. Chairman, our time has been much foreshortened, and the whole presentation of the papers of this group will take approximately 1 hour. I would wonder whether under the circumstances you wish us to proceed with some areas only, or may we present what we came prepared to offer?

Senator NELSON. Your statements will be printed in full in the record. I have one major statement. Are there prepared statements other than this one?

Mr. HANOLD. I think each of us has a statement.

Senator NELSON. This says "Statement by the Grocery Manufacturers of America."

Mr. HANOLD. All the statements are there, I am informed.

Senator NELSON. These are all together. Well, they will be printed in full in the record.

I think it might be helpful if you could do some summarizing, if it wouldn't handicap your presentation, because we are just going to get interrupted every so often with rollcalls.

Unfortunately, this is not a very good time of the year to have scheduled hearings, because we are getting near the end of the session and have a lot of rollcalls.

You can read from the text if you wish. It would be helpful if you could do some summarizing as you go along.

Mr. HANOLD. I will use a great deal of brevity on my own.

NUTRITIONAL STANDARD-SETTING AND LABELING FOR FOOD

Mr. Chairman and members of the committee, the committee has invited testimony relating to nutritional standard setting and labeling for food, a subject of vital concern to GMA's members, the Nation's leading manufacturers of food products.

GMA supports the concept of voluntary nutritional quality guidelines for formulated foods and first set out this support in documents to the Commissioner of the Food and Drug Administration in October 1970.

GMA is also on record in support of the general principle of voluntary nutritional labeling.

On March 30, 1972, FDA published for comment proposed criteria for nutritional labeling. GMA has been actively involved in working toward this proposal since June of 1970. At that time Commissioner Edwards asked GMA to form a task force to work with the agency in ascertaining how labeling could be improved by voluntary industry action to convey to the consumer an understanding of the nutritional composition of food products.

Industry has been criticized for being overly critical of FDA's proposal.

At the onset, let me say that while we support nutrition labeling, the details of the final proposal must be wrought from the careful deliberations of consumers, industry, and the regulatory agency.

As the labeling proposal now stands, there are certain elements which make such a voluntary program less than feasible to implement. GMA has filed comments on the proposal with FDA in hopes that these difficulties can be cleared up and a viable program can be established.

COMMENTS ON FDA'S ADDITIVE PROGRAM

With that introduction, let me introduce Mr. Creger, to carry forward on the comments on the FDA's additive program.

STATEMENT OF JOHN CREGER, SENIOR ATTORNEY,
KRAFTCO CORP.

Mr. CREGER. Thank you.

I was asked to discuss today the program of the Food and Drug Administration with respect to food additives, and to give a synopsis of current regulatory activities in regard to food chemicals generally. The Food and Drug Administration has embarked on an intensive program bringing to bear its sophisticated techniques and knowledge upon a broad range of questions involving food safety.

Much of this activity has taken place since the hearings before the Subcommittee on Executive Reorganization and Government Research of the Senate Committee on Government Operations, on April 6 and 7,

1971.

On June 25, 1971, FDA published new regulations governing the eligibility of substances for classification as generally recognized as safe in food.

In general, the GRAS criteria divide food substance into the following categories:

1. Those substances which are generally recognized as safe; 2. Those substances which will be accorded GRAS status after review by FDA; and

3. Those substances which are not eligible for GRAS status and, thus require a food additive regulation under section 409 of the Federal Food, Drug, and Cosmetic Act.

Mr. HANOLD. Our next witness, Mr. Chairman

Senator NELSON. Just a moment, I wonder if I could ask a question. In your first line, Mr. Creger, you stated:

There have been some suggestions as to the advisability of changing the system under which food additives, and, indeed, our total food supply is regulated. I suggest that any change may not benefit the American consumer.

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