and the pharmaceutical profession, the officers and scientific grou in the Government, in the Public Health Service and in the Fo and Drug Administration, and also the scientific representatives o industry; and I wish to at this time publicly acknowledge the very great debt that medicine and pharmacy owe to the scientific repre sentatives of a number of important drug firms who have assiste greatly in the establishment of standards, and who often have been pioneers in many new developments and who have given of thei time and often spent their own funds in researches which have helped establish better standards. An illustration of that has come in one of the very recent interim revisions, the setting up of the new stand. ard, and the determination of new standards for determining the vitamin potency of cod liver oil, in which the Government officials. Food and Drug Administration officials, representatives of the Public Health Service, the scientific representatives, the experts of this country in the vitamin research-such men as Dr. Mendel and Dr. Sherman and Dr. McCollum, Dr. Dutcher, Dr. Steenbach, and . others, men who are internationally known for their knowledge of : vitamin therapy and vitamin standardization as well as the scientific representatives of a dozen or more large pharmaceutical houses who i are producing vitamin products. This scientific group met in public conferences and their discussions have been given freely to the world. Their conferences have been stenographically reported to not only the scientists in this country but to the scientists in the vitamin field in Europe, and those groups have combined in establishing new standards of vitamin potency of cod liver oil, which is now being specially administered by the U.S.P. vitamin board consisting of a representative of the Government and two other scientific vitamin experts. This is typical of the type of service which we have been able to secure, through many years, through this cooperation between Government officials, purely scientific men and the scientific groups in an industry of this type where the professional ideals have very definitely predominated, and these conferences are public, with no secrets, and that is one of the strengths of the pharmacopoeial work for it is able to bring this large group of scientific men into voluntary service to the people of the United States, administered through the Government officials. Thank you for the privilege of speaking. The CHAIRMAN. Mr. Charles M. Cox.

STATEMENT OF CHARLES M. COX, REPRESENTING THE NATIONAL ASSOCIATION OF FEED MANUFACTURERS; PRESIDENT OF THE NEW ENGLAND GRAIN & PRODUCTS CO.

Mr. Cox. Gentlemen of the committee. I represent the National Association of Feed Manufacturers, and also my own corporation, of which I am president, called the New England Grain Products Co. So far as I know I am the only person here--I certainly was at the last hearing-who had anything to say in regard to the matter of feeds for cattle, poultry, and other animals. It is, however, a very large industry, both in point of value to the country and in dollars and cents. I am located in New England, and we of the East are the best customers that you of the Middle West and the South have for your cereal food products, including in that, perhaps, cottonseed

meal, which is not a cereal. Our own corporation in New England alone handles in excess of 50 carloads of products of this character a day, and there are brought into New England not less than 300 carloads of prepared foods a day for cattle and poultry and horses and pigs, and so forth. We feel, therefore, that we are entitled to considerable respect in a hearing of this kind, although we are not represented by a large number of people.

The development of prepared feeds for cattle and poultry has gone forward about on the same lines as the prepared foods for human beings. It dates back about 32 years, and now in the Eastern part of the country almost all of the "critters ", so to speak, are fed on these prepared feeds, rather than being fed on so many oats and so much corn and so forth.

It has been found a satisfactory development, and when I say that it means a great deal, because the men and women who are studying the problem of getting a living from keeping hens are very studious, careful people. They do the thing which makes for the result. They spend their money very thoughtfully and they are buying these prepared products constantly.

Gentlemen, we feel that we are big enough to ask of you to be kind enough to give us a bill all of our own, that we should not be included with cosmetics, that we should not be included with human foods.

Senator OVERTON. It looks as though you are the only witness who wants a bill. The others are all opposing bills.

Mr. Cox. We have no objection to Government regulation, Senator. We are regulated up to our eyes, and we do not object to it. Almost every State in the Union has an experiment station. There are six of them in the New England States; they are all helpful to us, and we try to be helpful to them. Our own concern maintains a group of five men, who are doing nothing but studying the poultry situation. They cost us a lot of money.

Senator OVERTON. Have you a prepared bill to submit?

Mr. Cox. I have not a bill, sir. I will be delighted to prepare one, if you ask me to.

Šenator OVERTON. I will be very glad if you would.

Mr. Cox. I was here at the former hearing and Senator McNary spoke of this, somewhat favorably, Senator. We will have a bill prepared for you. Do you wish to hear me about my story now? Senator OVERTON. Yes.

The CHAIRMAN. Yes.

Senator OVERTON. I just thought perhaps you had a bill.

Mr. Cox. Well, we did not receive encouragement at the former hearing to warrant our doing that, but we will do it.

I might say that the feeding of animals and poultry is far more scientific than is the feeding of you and me and other human beings. A grocer sells what his customers demand. A hen eats what she gets: and the hens are tested constantly, and I am speaking from experience. She is trap-nested, and if she does not lay a reasonable number of eggs, she is killed for meat, and there is no business in this country more scientifically carried on than is this matter of raising poultry in the eastern section of our country and the feed which does not yield a result does not continue to exist. Our whole

ADVISORY BOARD OF THE AMERICAN PURE FOOD LEAGUE

Samuel Hopkins Adams, Lh.D., author, New York, N.Y.; Robert M. Allen, Kentucky food and drug control, 1902-16, special assistant to United States Attorney General, 1908–9 prosecutions under food and drugs act, New York; W. M. Allen, State food chemist, North Carolina; Carl L. Alsberg, M.D., director Food Research Institute, Stanford University, California; Theodore B. Appel, M.D., secretary of health, Harrisburg, Pa.; Lewis B. Allyn, food specialist, Westfield, Mass.; E. M. Bailey, Ph.D., chemist in charge experiment station, Connecticut; T. B. Beatty, M.D., State health commissioner, Salt Lake City, Utah; E. L. Bishop, M.D., health commissioner, Nashville, Tenn.; Alice F. Blood, School of Household Economics, Simmons College, Boston, Mass.; F. C. Brezeal, director dairy and food division, State department of agriculture, Richmond, Va.; Lucius P. Brown, Ph.D., former food official, Tennessee; Mary de Garmo Bryan, institution management, Teachers College, Columbia University, New York, N.Y.; Bailey B. Burritt, general director Association for Improving Condition of the Poor, New York, N.Y.; Laura A. Cauble, chairman department public welfare, New York City, Federation Women's Clubs, New York, N.Y.; E. M. Chamot, Ph.D., department of chemistry, Cornell University, New York, N.Y.; Caroline Bartlett Crane, lecturer, Kalamazoo, Mich.; W. G. Cogswell, M.D., secretary State board of health, Helena, Mont.; Charles F. Dalton, M.D., secretary and executive officer State health department, Vermont; Thomas I. Dalton, Ph.C., assistant chief food and drug inspector, Topeka, Kans.; Kate Daum, director nutrition department, the State University of Iowa, Iowa City, Iowa; S. C. Dinsmore, food and drug commissioner, Reno, Nev.; Thomas Dreier, chairman State development commission, Melvin Village, N.H.; J. Roslyn Earp, M.D., director bureau of public health, Santa Fe, N.Mex.; Richard Fischer, Ph.D., professor of chemistry, University of Wisconsin, Madison, Wis.; Kathryn Ford, president The League of Insurance Women, New York, N.Y.; Guy G. Frary, State chemist, Vermillion, S.Dak.; Mrs. Franklin W. Fritchey, president American Homemakers Association, Baltimore, Md.; Sister John Gabriel, House of Providence, Mount St. Vincent, Seattle, Wash.; S. Margaret Gillam, director department of nutrition, The Society of New York Hospital, New York, N.Y.; Friend B. Gilpin, M.D., Cranford, N.J.; George W. Goler, M.D., former health officer, Rochester, N.Y.; W. B. Grayson, M.D., State health officer, Little Rock, Ark.; Mrs. Otto Hahn, president Home Makers' Forum, Inc. New York, N.Y.; Worth Hale, M.D., assistant dean Medical School, Harvard University, Boston, Mass.; Alice Hamilton, M.D., School of Public Health, Harvard University, Boston, Mass.; W. F. Hand, Ph.D., State chemist, A. and M. College, Mississippi; Charles Hansel, president Union County park commission, civil engineer, railroad valuation expert, Cranford, N.J.; Norman Hapgood, writer, New York, N.Y.; H. D. Haskins, B.S., official chemist Massachusetts agricultural experiment station, Amherst, Mass.; Charles D. Howard, S.B., director chemistry and sanitation department, Concord, N.H.; S. S. Huebner, Ph.D., Wharton School of Finance, University of Pennsylvania, dean College of Life Underwriters, president American Association of University Teachers of Insurance; James W. Kellogg, Ph.D., chemist, director bureau of foods, Harrisburg, Pa.; Helen S. Kimball, nutrition-milk, New York, N.Y.; Harry Klueter, chief chemist department of agriculture, Wisconsin; E. C. Koerth, director bureau foods and drugs, Austin, Tex.; C. S. Ladd, chemist, State food commissioner, Bismarck, N.Dak.; Martin L. Lang, division of public health, State food and drug commission, Indianapolis, Ind.; Harold A. Ley, president, The Life Extension Institute, New York, N.Y.; William Loeb, secretary to President Theodore Roosevelt, New York, N.Y.; W. H. McIntire, Ph.D., head department of chemistry, agricultural experiment station, University of Tennessee, Tennessee; Icie G. Macy, Ph.D., director research laboratory, Children's fund of Michigan, Detroit, Mich.; E. V. McCollum, Ph.D., the Johns Hopkins University, Baltimore, Md.; Arthur E. McClue, M.D., State health commissioner, West Virginia; A. T. McCormack, M.D., State health officer, Louisville, Ky.; J. Lynn Mahaffey, M.D., director of health, Trenton, N.J.; Abby L. Marlatt, director home economics courses, University of Wisconsin, Madison, Wis.; E. E. Meares, insurance executive, New York, N.Y.; Day Monroe, professor of home economics, State College of Home Economics, Cornell University, New York; E. Garrido Morales, M.D., director bureau foods and drugs, San Juan, P.R.; Hazel E. Munsell, Ph.D., nutrition studies section, Bureau Home Economics, United States Department of Agriculture, Washington, D.C.;

Mrs. Frederick Nathan, former president New York City Consumers League, New York, N.Y.; Geoffrey O'Hara, lecturer, New York; J. A. O'Hara, M.D., president State health department, Louisiana; Emma Dot Partridge, advertising, New York, N.Y.; H. J. Patterson, Ph.D., director and dean University of Maryland, Maryland; M. E. Pennington, Ph.D., perishable foods, New York, N.Y.; A. M. Peter, emeritus professor of chemistry, University of Kentucky, Lexington, Ky.; Wilbur C. Phillips, author, New York, N.Y.; Anne L. Pierce, writer, food specialist, New York, N.Y.; Arthur L. Prince, assistant soil chemist agricultural experiment station, Trenton, N.J.; E. L. Redfern, chief chemist department of agriculture, Des Moines, Iowa; Lydia J. Roberts, chairman home economics department, University of Illinois, Chicago, Ill.; Frances Eastman Rose, M. D., Spokane, Wash.; R. W. Ruprecht, Ph.D., chemist, head of department chemistry and soils, agricultural experiment station, Florida; Wm. J. Schieffelin, M.D., chairman committee of 1,000, New York, N.Y.; Florence Brown Sherbon, M.D., department of home economics, the University of Kansas, Lawrence, Kans.; Florence H. Smith, assistant professor nutrition, University of Chicago, Chicago, Ill.; A. M. G. Soule, chief of food division, department of agriculture, Augusta, Maine; Harry Steenbock, Ph.D., Wisconsin agricultural experiment station, Madison, Wis.; John A. Stevenson, insurance executive, Philadelphia, Pa.; A. L. Sullivan, State food and drug commissioner, Baltimore, Md.; Geo. C. Truman, M.D., superintendent State board of health, Arizona; W. J. Warner, commissioner food and dairy departments, Connecticut; Ruth Wheeler, Ph.D., director Institute of Euthenics, Vassar College, Poughkeepsie, N.Y.; Ira S. Wile, M.D., New York, N.Y.; Edna Noble White, M.D., director Merrill-Palmer School, Detroit, Mich.; Noah Zehr, M.D., Fort Wayne, Ind.

Mr. ALLEN. Under date of February 6, 1934, and at the request of Mrs. Wiley, president, and Miss Alice Lakey, secretary, I sent them a statement on Senate bill 1944 with reference to some of the amendments carried into Senate bill 2000. This statement was sent to all members of the advisory board. There has been no adverse comment. Those who have replied seem to have received it with rather high commendation.

This statement is as follows:

Mrs. HARVEY W. WILEY, President,
Miss ALICE LAKEY, Secretary,

NEW YORK, N.Y., February 6, 1934.

American Pure Food League, Cranford, N.J.

DEAR MRS. WILEY AND MISS LAKEY: You have asked me, among others, to study and present a statement about Senate bill 1944, the so-called "Tugwell bill" and the substitute Senate bill 2000. Memoranda on some of the provisions have been sent you. Miss Lakey has asked for a shorter summary of this

material.

Also I have Miss Lakey's note asking for comment on a circular letter with an enclosed pamphlet entitled “Emergency Legislation versus Permanent Legislation", opposing these bills and sent from the joint committee for sound and democratic consumer legislation, which is headed, as shown on the letterhead, by Lee H. Bristol, vice president Bristol-Myers, Inc.; S. B. Colgate, president Colgate-Palmolive-Peet Co.; K. F. MacLellan, president United Biscuit Co. of America; Ellery W. Mann, president Zonite Products, Inc.; Edward J. Noble, president Life Savers, Inc.; Arthur R. Wendell, vice president Wheatena Corporation.

Senate bill 1944, the bill drafted and sponsored by the present administration and the State food and drug commissioners, is not emergency legislation, but needed permanent legislation. It is more in line with existing State laws than the existing act of 1906, and all of the good in that act seems to have been continued into Senate bill 1944.

I had charge of the Kentucky work from 1902 to 1916, including a year and a half as a Special Assistant to United States Attorney Generals in litigation arising under the Federal law. Since then there has been some rather extended experience directly or indirectly with the expenditure of large sums in food advertising.

Senate bill 1944 is written out of the best experience had during the last 30 or more years in food and drug control. Its provisions are honest, the administrative provisions fair, very fair, with far more protection to the

manufacturer and dealer against hasty action than is contained in the existing

law.

Senate bill 1944 has the approval of Dr. Carl Alsberg, who succeeded Dr. Wiley as Chief of the Bureau of Chemistry, in the enforcement of the existing law. Mr. Campbell, present Chief of the Food and Drug Inspection Service and his associates, long experienced in this work, certify the provisions as needed.

Senate bill 1944 has been considered and has the approval of the Association of State Food and Drug Control Officials; the approval of the American Public Health Association and the American Home Economics Association and has, I understand, the approval of the Association of Official Agricultural Chemists, who in the main are connected with the State agricultural experiment stations.

These groups make up that sound foundation upon which honest food, drug and cosmetic manufacturers, and dealers can have full and lasting confidence with the consuming public as well as protection to consumers. Honest food, drug and cosmetic manufacturers, and consumers should thoroughly investigate the arguments the opposition make against the bill before they allow this needed protection to honest business and to human health to be delayed, weakened or set aside.

The article by Mr. Charles D. Howard, State analyst and State food-control official of New Hampshire, published in the January bulletin of the board of health of that State, entitled "The Federal Food and Drug Bill", should be widely read. Mr. Howard points out:

"Much of it (the opposition) as is the case with all control legislation, arises from honest misapprehension. So far as the food industry is concerned, this is now for the most part on an honest basis, and the same is true of the manufacture and distribution of official pharmaceuticals. The various elements in these industries are for the most part very well intentioned. They are disposed to do the right thing, and thus far they have voiced comparatively little opposition."

It is seldom that Mr. Howard takes out his sword. He is a man of peace, trying first to persuade people in the trade to do the right thing. He takes his sword out on this occasion with a thrust as follows:

"An outstanding feature of this bill, and the one that is now causing a prodigious hullabaloo in certain quarters, is the seemingly reasonable proposal that we shall have truthful advertising of foods, remedials, and cosmetics. Only Heaven and the enforcement officials have any adequate appreciation of the present pernicious and widespread abuses in this respect and of the crying need for reform. Yet, with peculiar appropriateness-with an opposition running true to form-this proposal is being met by a highly organized campaign the weapons of which are derision, sneers, appeals to prejudice and ignorance, misrepresentation and downright lying."

THE OBJECTIONS TO THE BILL

The circular put out by the "Joint Committee for Sound and Democratic Consumer Legislation" quotes Dr. James H. Beal, chairman of the board of trustees of the United States Pharmacopoeia, as follows:

"The success of the present Pure Food and Drugs Act in accomplishing its purpose has probably been greater than that of any other Federal enactment of equal scope, and that, as the result of the law, misbranded and falsely and fraudulently labeled foods and drugs are practically things of the past."

Consumers are sold by advertising. It should follow that law which has accomplished so much in the labeling of foods and drugs should now be applied so as to eliminate the same abuses in advertising since customers are sold and make their purchase before reading the label.

This committee makes the argument in the main that the existing bill is so good and has accomplished so much that it should be left as it is. They say: "The past 27 years, it is pointed out, have produced a serious of interpretations of the act which were essential to its success, and essential to the wellbeing of public health."

"Opponents of an entirely new law say that in view of the experience of the present act, it obviously would be unfortunate for industry, for the Department of Agriculture, and for the public at large, if the suggested new legislative