*

minute traces or their relationship to previously identified levels has not been established. What is the importance of the fact that residues have only been identified in a small percentage of liver 12 and a few kidneys? What is the relationship of this to our total 12 beef supply? Are other means available to monitor and control potentially contaminated livers. Not all routes of original administration have even been identified with residue problems.

W

The fact that DES is widely used and yet well over 97% of the government's objectively collected samples have shown no trace, bears undisputable evidence that the product is being safely used. We need to determine then, what management and manufacturing practices need to be applied in those isolated instances to insure that no residues will occur in violation to regulation.

And finally, what constitutes none? It has been stated on many occasions by competent scientific investigators that mankind, our environment, Mother Nature, herself, could not comply with an absolute zero attitude on anything. These are not answers for me to determine. These are topics and discussions that need to be heard. For this reason ANCA heartily endorses the efforts of FDA to bring this matter out in the open before taking further action. We feel confident that these hearings will bring to light opportunities to solve problems and allow continued use of this tool. Take away a tool responsible for a ten percent advantage in efficiency of production, and that cost will be reflected throughout the chain of production all the way to the consumer.

On the other hand, the unquestioned confidence of the consumer is the most valuable asset of the American agricultural producer. DES or any other product is of no value if it hinders product quality, wholesomeness, or safety. Such determination, however, must be based on fact, not emotion; true relevance, not speculative potentiality, and above all, reason must bear some influence on a logical conclusion.

H

Senator KENNEDY. Thank you very much. I appreciate your appear ance here.

At this point I order printed all statements of those who could not attend and other pertinent material submitted for the record. (The material referred to follows:)

S

ཏན།ཉོཕོག་་བ་ཏོཏི

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CONSUMER ACTION NOW, INC., 815 PARK AVENUE, NEW YORK, N.Y. 10021

July 21, 1972

Corinna Bazarini

Eleanor Bissinger
Judy Dwoskin

Jean Fox

Tiiu Frankfurt

Ilene Goldman

Joan Gussow
Susan Heath
Vivian Horner
Irmgard Hunt
Gay Lord
Jean McCarroll

Barbara Maltby
Carlin Masterson
Maureen Myers
Maryann Napoli
Barbara Niles
Tina Peterman
Lola Redford
Cynthia Stein
Linda Stewart
Arlene Weltman
Mary Whitesides

Honorable Edward M. Kennedy

House Sub-Committee of the Senate Labor and
Public Welfare Committee

The Senate Office Building

Washington, D.C.

Dear Senator Kennedy,

Unfortunately, we at Consumer Action Now were not in-
formed of the hearing on S. 2818 in time to have one
of our group testify. However, this letter is an effort
to record the views of the membership and subscriber-
shipof C.A.N. on the use of diethylstilbestrol in the
feed of U. S. meat animals.

Our feeling regarding the use of D.E.S. is one of concern and our reasons are as follows:

D.E.S. at some dosage levels is a known carcin-
ogen.

The existence of D.E.S. residues in animal livers
tested.

the lack of more sensitive testing procedures for
residues.

The nature and infrequency of existing testing.
The incidence of vaginal cancers in young women
whose mothers were given D.E.S. to prevent mis-
carriage during pregnancy.

We receive many requests for information of an environ-
mental nature by letter and phone at the C.A.N. office.
It should be of interest to your committee that questions
and concern about D.E.S. are second only to those in-
volving the solid waste problem. The hundreds of letters
questioning the safety of the use of diethylstilbestrol
convince us that this concern is general and not confined
to a small group of "food faddists".

The law says that additives shall be proven safe before
entering our food supply. In our judgement, D.E.S. has
not been proven safe. We find it particularly disturbing
that even though the withdrawal period has been extended,
residues continue to be found.

Recycled paper saves trees. This is recycled paper.

BEFORE THE

HEALTH SUBCOMMITTEE

OF THE

SENATE LABOR AND PUBLIC WELFARE COMMITTEE

STATEMENT ON BEHALF OF VINELAND LABORATORIES, INC.

P. O. BOX 70, VINELAND, NEW JERSEY 08260

This statement is submitted in behalf of Vineland Laboratories, Inc. for inclusion in the record of the Subcommittee's hearing held July 20, 1972 to consider actions now pending with regard to the withdrawal of approval of new animal drug applications for diethylstilbestrol (DES), and to consider S. 2818 which would ban DES from use in animal feed. Vineland Laboratories, Inc. holds a new animal drug application for the use of DES in implants. Its current authorization is NADA No. 10964.

The rigid safety standard imposed by the applicable law and regulations, i.e., that no detectable residue of DES may exist in edible portions of animal carcasses, is met fully when DES is administered by the use of implants in accordance with approved conditions specified in the applicable label instructions. testing and the use of the new chemical method of assay there has been no instance of detectable residues of DES from implanted animals. This was confirmed by Commissioner Edwards' statement before the Subcommittee

Even with the recently increased