the pending legislation would both modernize and re-write this authority into a single Federal Meat Inspection Act, which will undoubtedly be more effective in carrying out the purposes of the meat inspection program; and 3. It would definitely extend meat inspection by establishing cooperative Federal-State inspection systems and offer significant encouragement and incentive to states for providing state inspection that is consistent with Federal requirements.

With these broad statements of purpose, we will confine the remaining comments in this presentation to arguments in favor of the legislation and in refutation of some of the arguments that have been proposed against it.

We hasten to state that under present circumstances and procedures by far the vast majority of meat offered to consumers in commerce is absolutely safe and wholesome, being processed, handled, and manufactured under sanitary conditions that are without parallel in the entire world. To the best of our knowledge, most persons and firms engaged in these operations are honorable, and generally adhere to those practices and procedures which are necessary to assure the excellence of the product in the trade.

On the other hand, there are apparently those who choose to disregard ethical practices and honesty, and deliberately inject unwholesome products and those not fit for human consumption into trade channels. Without question, the manufacturing and processing end of the business lends itself to unethical practice, because of the extreme difficulty in detecting undesirable ingredients once they become part of manufactured or processed products. Likewise, it may be impossible to detect diseases in animals by merely inspecting the carcasses without having made ante-mortem, as well as post-mortem, examination.

In the debate that has occurred on the legislation so far, both in Committee and on the floor of the Congress, as well as in the press, there has been little argument against tightening up the Federal authority, and extending it to a degree necessary to protect consumers. The main objection to the legislation has been that it does not go far enough and should extend Federal authority to cover intrastate establishments, at least thse doing more than a given volume of annual business. The argument has been that states will not improve their present programs to comply with Federal requirements, or enact such legislation as may be necessary in order to provide the necessary protection and be eligible for State-Federal cooperative arrangements. Furthermore, by inference, at least, it has been charged that any meat slaughtered and processed under Federal inspection was probably safe and wholesome, whereas, any animal slaughtered and products processed without Federal inspection were not safe and wholesome, or at least were subject to suspicion.

Presently, about 85% of meat animals slaughtered in the United States are slaughtered under Federal inspection and about 75% of meat processed, is also subject to Federal inspection. These figures, of course, do not include that number of animals and that volume of processed meat which is inspected by those states now having meat inspection laws.

Furthermore, they do not include those animals and products slaughtered and processed by those honorable people who are not subject to inspection of any kind, but still are concerned about the safety of the meat supply, and employ those practices, as well as maintain the degree of sanitation necessary to produce safe, and wholesome meat. It should also be kept in mind that currently those intrastate slaughtering establishments which request the Federal grading of their carcasses must also meet rigid inspection requirements in order to be eligible for the grading service.

Even so, we must acknowledge that there are instances in various meat establishments which currently are deplorable and rather frightening. To conclude, though, that any meat produced and processed in a plant that does not have federal inspection is unsafe, unwholesome, or suspect, is absolutely erroneous, and an obvious attempt to exaggerate the situation. The truth of the matter is that some of the most flagrant situations which have been discovered in recent months have occurred in plants having Federal inspection. This has been possible only because the present authority of the Federal system needs to be strengthened in order to stop this flow of illegal traffic.

We believe that H.R. 12144 will satisfactorily answer the needs of the industry and protect the consuming public. It does provide for clarifying meat inspection procedures, for extending Federal authority to cover horses, mules, and other equines, for tightening up the jurisdiction of the inspection service with respect to adulterated meat or meat food products, for improving labeling requirements,

and also extending the authority to brokers, renderers, importers, warehouses, and other sellers of meat.

Furthermore, the legislation would extend the authority of the Secretary to require intrastate establishments to register, to keep such records as are necessary, to fully and correctly disclose all transactions involved in their business, to permit access to these records, and to allow that reasonable samples of their inventory can be taken. This authority should not be confused with authority to require Federal inspection.

We do feel the procedures are very necessary in order to permit adequate surveillance at sources where adulterated products or products not suitable for human consumption can be illegally put into commerce. They allow for investigation at the beginning of possible illegal traffic and for an opportunity to trace any such traffic from its source; whereas, without this authority, Federal officials would only be able to intercept products in question at some point in the channels of commerce, and would be seriously handicapped in efforts to determine where such products had their origin.

Without this authority for access and in order to carry out the objectives of a satisfactory meat inspection service, we visualize the only probably alternative would be an extension of federal inspection into states that refuse to develop a satisfactory inspection program covering intrastate establishments and operations. This alternative, of course, has already been proposed and defended vigorously. However, at least some of the proposals would not cover all intrastate establishments, leaving several thousand smaller operations either without inspection, or as a responsibility of a state. Such entry into what we believe should be state authority, would definitely tend to destroy the incentive for states to set up their own system of inspection according to Federal requirements, and thus be eligible for State-Federal cooperation and the financial assistance which would be provided.

We also feel that one very important provision included in H.R. 12144 is that dealing with requirements pertaining to imported meat. Section 10 of Title I states that no meat or meat food products which are capable of use as human food shall be imported into the United States if such articles are adulterated or misbranded, and "unless they comply with all the inspection, building construction standards, and all other provisions of this Act and regulations issued thereunder applicable to such articles in commerce within the United States". The same quoted language is not included in S. 2147, nor was it contained in H.R. 6168, but was an amendment by the House Committee on Agriculture, and is now part of H.R. 12144. This Association strongly recommends the retention of this language to assure that imported meat is as safe and wholesome as that produced domestically.

While we have not gone into the fine details and provisions of the pending legislation, this in no way means that we have not thoroughly analyzed every paragraph, provision, section, and title of the bill to which we have referred. Instead, we have thoroughly appraised its application to the problems involved, and conferred on numerous occasions with officials of the Department of Agriculture making our advice and counsel available to them in the preparation of the original legislation. Thus we are complimented by the fact that H.R. 12144 does conform with what we believe is appropriate and necessary legislation in order to protect the consuming public and assure a safe and wholesome supply of meat to the greatest extent that is possible.

With these comments, therefore, we do recommend H.R. 12144 to the Committee on Agriculture and Forestry and to the entire United States Senate, and trust it will be given favorable and speedy consideration.

Hon. B. EVERETT JORDAN,

SALT LAKE CITY, UTAH, November 9, 1967.

Chairman, Subcommittee on Agricultural

Research and General Legislation,

Senate Committee on Agriculture,

Senate Office Building,

Washington, D.C.

DEAR SENATOR JORDAN: The National Wool Growers Association represents sheep producers in a 22-state area where 86 per cent of the nation's sheep, lambs and wool are produced.

This is to advise that our organization supports H.R. 12144 as it was passed by the House.

We will appreciate it very much if you will include this letter in the record of the hearings you are now conducting on meat inspection bills.

Sincerely,

EDWIN E. MARSH,

Executive Secretary, National Wool Growers Association.

STATEMENT OF M. R. CLARKSON, EXECUTIVE SECRETARY, AMERICAN VETERINARY

MEDICAL ASSOCIATION

Mr. Chairman, and members of the Committee, the American Veterinary Medical Association appreciates this opportunity to present its views to the Committee, in connection with proposed legislation to amend and extend the Federal Meat Inspection Act. The meat inspection program, to insure the wholesomeness of meats moving in commerce, is one of the oldest and strongest veterinary activities of the Federal government. It is the model for similar programs in the states and in many foreign countries.

We are glad to see that H.R. 12144, if enacted, would preserve, intact, the essential provisions of the current Federal Meat Inspection Act. The 1906 Act, buttressed by several Supreme Court decisions, provided the underlying authority for flexibility in administration, with ample powers of regulatory action by the Secretary. Thus, it has been possible for the Department to amend the meat inspection procedures and requirements as necessary to cope with changes in the meat packing industry, varying patterns of the spread of animal diseases, new threats posed by the possibilities of residues of drugs, pesticides, and other chemicals, the developing technology of meat-food product preparation, and dramatic changes in consumer preferences for meats. We trust that in the consideration of this legislation, to confer additional powers upon the Secretary of Agriculture, there will be no impairment of the flexibility of administrative action which is so necessary to the day-to-day conduct of a viable meat inspection program.

Our Association feels that there are three general criteria against which the proposed legislation should be measured.

1. It should maintain the excellent quality of the Federal meat inspection program.

2. It should provide for realistic Federal-State cooperation which will support and enhance the quality of the total program.

3. It should provide clear, uncomplicated, lines of authority and responsibility for administration of the Act.

We believe the proposed legislation would accomplish these purposes if amended to place clear, undivided responsibility upon the Secretary of Agriculture for the administration of the Act.

Mr. Chairman, the Meat Inspection Act is enforced by procedures which are far different from those used in the enforcement of the Federal Food, Drug and Cosmetic Act, and the counterpart Pure Food and Drug Acts of the States. Every hour of every day, meat inspectors working directly with the slaughtering and processing crews in the packing plants, authorize placing the stamps of approval of the Secretary of Agriculture on large quantities of meat; or, conversely, they deny this approval and require that the meat be condemned and destroyed, or held for further attention.

Regulations and instructions must be clear and uniform. On the effective date of any new regulation, the changes are put into effect without delay by the inspectors in the meat packing plants.

Clear and untrammeled lines of authority and responsibility are necessary for the guidance of inspectors, and for the handling of appeals by packers and others who are affected by the inspection procedures. Day-to-day guidance of inspectors and prompt appeals cannot be handled effectively by committee, nor can they be handled by two cabinet officers with concurrent jurisdiction, each with his corps of specialists and advisors.

We recommend that all Federal authority over meats and meat-food products, and the animals from which they are derived, as delegated by this legislation, be conferred entirely and unequivocally upon the Secretary of Agriculture. To accomplish this, we consider the following changes to be necessary in the text of H.R. 12144.

1. On page 15, line 2, place a period after the word "articles" and strike the rest of that paragraph.

2. On page 20, lines 10 and 11, strike the words "and the Federal Food, Drug, and Cosmetic Act."

3. On page 40, lines 18 through 25, and on page 41, lines 1 through 8, strike all of section 409.

With these three changes, Mr. Chairman, with the additional authorities conferred under the provisions of this bill, and the retention of Section 902B of the Food, Drug and Cosmetic Act, exempting meat and meat-food products covered by the Meat Inspection Act, from the provisions of the Food, Drug, and Cosmetic Act, it should be perfectly clear that jurisdiction and responsibility for all aspects of wholesomeness, proper labeling, the setting of standards of identity, the establishment of tolerances for chemicals and the packaging and handling of meats and meat-food products covered by the Federal Meat Inspection Act, is exclusively the province of the Secretary of Agriculture. This is important, not only from the standpoint of the orderly administration of the Federal Act, but also to give full meaning to the proposed new provisions for cooperation with the States. Responsible State officials should be able to align their requirements for State inspection in accord with the cooperating Federal agency, without having to coordinate their activities, also, with the requirements of a second Federal department.

Mr. Chairman, again we thank you and the other members of the Committee for this opportunity to present the views of the American Veterinary Medical Association. I am authorized to say that our Association favors passage of the bill, if amended as indicated in this statement.

Senator HARRY F. BYRD, Jr.,

WASHINGTON, D.C., November 16, 1967.

Acting Chairman, Subcommittee on Agricultural Research and General Legislation, Senate Committee on Agriculture and Forestry, Washington, D.C. DEAR SENATOR BYRD: When the Committee on Agriculture of the House of Representatives had under study earlier this year legislation to make federal meat inspection practices more effective and in the interest of greater consumer protection, the Cooperative League of the USA communicated its views on this important subject to the Subcommittee Chairman whose members explored this subject from many angles.

It was disappointing that the measure finally adopted by the House of Representatives omitted the more complete coverage of meat inspection we had hoped for.

We are glad members of your subcommittee, notably Senator Mondale and Senator Montoya, are taking steps to strengthen in the Senate version the meat protection procedures covering plants operating intrastate. We especially applaud Senator Mondale's proposals because they become operative soon after passage of the Act, whereas there is a time-lag at this point in Senator Montoya's otherwise excellent proposal.

Among other things we told the House Subcommittee in this connection that "Because the Cooperative League of the USA for over fifty years has been voicing its concern for greater consumer protection in the nation's meat markets, the League is greatly interested in the meat inspection legislation now pending before your subcommittee.

"It has been apparent for some time that meat inspection procedures have fallen behind the needs of the 1960's and fallen behind developments within the industry.

"You have heard evidence that unwholesome and adulterated meat is finding its way into consumer channels. Some of this stems from the one-seventh of the meat slaughtered in the U.S. that is still not federally inspected.

"The League certainly does not want regulation for its own sake, but the relative effectivenss of federal inspection which now extends to six-sevenths of the meat slaughtered suggests the need for making the laws reach the small fraction which escapes federal inspection and which is where so many of the troubles for the consumer originate.

"In the intensely competitive meat industry it is not safe to rely too heavily on internal policing by the industry, for the small competitive advantages of

those who do not cooperate voluntarily are often enough to render ineffective this approach to good and safe handling procedures."

Adequate coverage is a key to effective meat inspection laws and both Senator Montoya's proposals and Senator Mondale's proposals make contributions to this need and deserve the subcommittee's careful consideration. We are sure the subcommittee will also recognize that in every exemption from the law's coverage are the seeds of future trouble for the American consumer, and while some exemptions are possibly unavoidable, they should be included only after the most rigid scrutiny of the case made for each particular one.

The Cooperative League of the USA applauds this renewed effort by your subcommittee to improve for American consumers the protection afforded them by present laws, some of which date back to the turn of the century. The need for these improvements is real and we wish you success in the effort, which will be more likely if you will take seriously into account the points we have made heretofore in our statement.

Sincerely yours,

SHELBY EDWARD SOUTHARD,
Cooperative League of the USA.

STATEMENT OF MRS. SYLVIA ZAGORIA, ASSISTANT TO THE GENERAL SECRETARY, NATIONAL CONSUMERS LEAGUE

The National Consumers League which, since 1899, has had an integral part of its program the protection of American consumers, wishes to go on record in favor of Senator Mondale's Bill (S. 2218) to amend the Meat Inspection Act.

The original Meat Inspection Act, passed 60 years ago, was a fine innovative program. However, 60 years is a long time. During that period, the industry has grown and changed. It is still changing and constantly expanding. The original law has long needed updating to keep up with these changes. We believe that S. 2218 will do much to update the law and extend it to provide urgently needed additional coverage.

The National Consumers League considers that one of the most important rights of the consumer is, as President Kennedy said in his 1962 message to Congress, "the right to safety—the right to be protected against the marketing of goods which are hazardous to health of life," and this is especially true in the area of foods. The value of a safe food supply to the health and well-being of each individual, as well as to the national security, is self evident. Moreover, the confidence of the consumer in the safety of our food supplies is a vital factor in the economic health of the food industry.

Yet, today, in buying meat and meat products, whether in the store or in eating establishments, the consumer cannot be sure that her purchase will be a safe and wholesome product. Consumers have only recently begun to learn that significant amounts of meat products are sold without ever having been subjected to any form of government inspection, and that approximately 15% of our meat supply (some 19 million animals), and 25% of our commercially processed meat products (some 8.75 billion pounds) are subject only to state or local inspection which varies from good to good-for-nothing. It is shocking that in 1967 there are still nine states which have no meat inspection laws at all. Do we need another Upton Sinclair to alert the public to the hazards of eating intra-state meat products in these states? Should we perhaps be campaigning for bill boards at state borders warning travellers when they are about to enter a state without meat inspection? It calls to mind the occasional signs I have come across during my travels where I have seen "non-potable" signs over water supplies. At least in that way the consumer got a fair warning.

But, of course, we know that even in those 41 states which do have inspection, the degree of protection varies greatly. Thirteen states have only voluntary programs. Two states require only mandatory licensing of packers with no provision for actual inspection of meat. Only 26 states provide for mandatory inspection of animals before and after slaughter, and only 25 states provide for mandatory inspection of processed meat products.

In such a chaotic situation, where safe, wholesome meat, properly inspected, may be lying side by side with meat produced under poor inspection, or no inspection at all, the consumer is at a great disadvantage. One more chore is added to the burden of making a wise choice in the marketplace. And this is a