of great value and assistance to the Committee in arriving at its findings in this matter. The next witness is Miss Alice L. Edwards of the American Home Economics Association.

STATEMENT OF MISS ALICE L. EDWARDS, EXECUTIVE SECRETARY OF THE AMERICAN HOME ECONOMICS ASSOCIATION

Miss EDWARDS. My name is Alice L. Edwards, Executive Secretary of the American Home Economics Association.

The American Home Economics Association is a professional organization of trained home economists, including approximately 9,000 members, with an organized association in each of the 48 States, the District of Columbia, Puerto Rico, and in Edmonton and Nova Scotia, Canada.

Through their study of household commodities home economists have become familiar with the provisions and administration of the present Food and Drugs Act. They know from experience that this act has been of untold value to consumers by protecting against impurities, adulteration, and false labeling; but they also realize that there are imperfections in the present law and that conditions have so changed since its enactment that the Government is unable to extend to consumers the protection originally intended.

The Association welcomes the opportunity to support the revision of the Food and Drugs Act and the extension of its functions to include the prevention of false advertising, to cover cosmetics, the control of drug products on the basis of therapeutic claims which are contrary to the general agreement of medical opinion, and the requirement of informative labels.

State laws alone will not suffice. A Federal or master law is required to prevent a hopeless lack of uniformity in regulations. Moreover, experience with the present act has proved that a Federal law will immeasurably strengthen State laws.

Home economists recognize the possibilities of advertising as a source of useful information about commodities and believe that truth in advertising called for by the proposed revision of the Food and Drugs Act would greatly increase public confidence in the claims made for worthy products. In our opinion, false or misleading statements in present-day advertising are rapidly destroying the faith of the public in all advertising, notably in the case of advertising by radio.

This has been the history in the case of false labeling. Twentyseven years ago it was argued that the regulation of labels would wreck the business of the manufacturer, even of reputable products, whereas it has increased the confidence of the consumer in such products. Unfortunately truth in labeling has not been sufficient for the protection of the consumer. The unscrupulous dealer still resorts to advertising as a means of giving the public unjustified confidence in his products by statements in advertising which he may not now put on the label. As a result, we realize that if the consumer is to be protected from such false or misleading claims, the advertising as well as the labeling must be subject to regulation. We believe that truth in advertising would prove even more advantageous to honest business than has truth in labeling.

We believe that a law to regulate advertising is needed and agree with a statement appearing in the November 23, 1933, issue of Advertising and Selling which reads:

Despite declarations of ethics, despite the establishment of regulatory boards, and despite the maintenance of high standards by individual publishers and advertisers, the fact that false, misleading, and harmful advertising still exists is undeniable. Abuses have not been controlled by intra-industry regulations.

*** These and other similar abuses cannot be definitely eradicated by regulations within the industry because (1) such regulations lack the united support of all members; (2) industry inertia defies effective action; and (3) the industry cannot impose penalties adequate to curb abuses.

That

The declaration that the public must be protected is no idle slogan. protection can be afforded only by a Federal law. The existing law has accomplished much but it falls far short of perfection.

Concern has been expressed by some that the provision in the bill which forbids labeling a drug as a cure for a disease when it is a palliative and not a specific cure would rob individuals of the privilege of self-medication.ˆ The answer to this is that the bill will not drive off the market legitimate products, truthfully labeled and advertised, and that to require them to be so labeled and advertised does not interfere with anyone's right to diagnose and treat himself; on the contrary it should make him feel safer in so doing.

Information as to the constituents in a commodity is essential if consumers are to profit from education and their experience in the use of a given commodity and to develop judgment in using them. We, therefore, heartily support the provision which requires the labeling of drugs as well as foods as to their ingredients.

May I, at this point, refer to the argument that is being used by canners and other food processors to omit grade labeling from the fair trade practices of marketing agreements or codes of their industries. They are urging that the use of such grade labeling "come about by due process of law", referring to the revision of the Food and Drugs Act now under consideration, however, a representative of the National Canners' Association at this hearing has asked that the proposed bill be so amended as to provide only for the labeling of substandard canned food.

The prices of canned foods are not reliable guides as to their quality. This is supported by numerous investigations by individual consumers in various parts of the country, including many by home economists; by the findings of the Federal Trade Commission; and by the judging tests carried on by canners themselves. The highest priced can is very frequently not the best, and the least expensive may prove to be a fancy grade. Therefore, we are forced to recognize that the consumer must seek some guide other than price as an indicator of quality.

One cannot be assured of obtaining a given quality by purchasing products from a certain State or locality. The quality of a nationally advertised brand may or may not be superior to that of nonnationally advertised goods. Furthermore the quality of a given brand does not always remain constant.

By a process of elimination through an examination of possible methods which might be used in determining quality, thoughtful consumers have come to believe that grade labeling of canned foods is essential if consumers are to be able to select these products intelligently.

Canners frequently comment on what seems to be the utter impossibility of developing clearly distinguishable grades of a sufficient number to inform the consumer of the shades of difference between various products. One can readily understand that a given canner wishes to gain the advantage of having his product put in the highest possible grade; but from the consumer's point of view fine shades of differentiation are neither desirable nor necessary, because their development would delay their use almost indefinitely and also because their enforcement would be very difficult and expensive. The use of four grades A, B, C, and Substandard would adequately serve the consumer's need. These would enable the housewife to select the truly superior product for those occasions and uses for which she wants an A grade; they would enable her to obtain a good medium grade for less exacting times and purposes, to select a C grade to use in certain dishes where the finer textures and flavors are masked, and to choose the substandard if rigid economy makes that necessary.

There is concrete evidence that it is possible to develop usable grades of canned foods. The grades for a considerable number of canned foods already promulgated by the Secretary of Agriculture and used in connection with the Warehousing Act are sufficiently satisfactory for the Government to use in connection with its own purchases of canned foods. Millions of dollars are loaned by the Reconstruction Finance Corporation and by bankers as well on foods graded by these standards. Furthermore, court decisions have proven these standards to be enforceable. If any of these grades are not well defined or prove unsatisfactory on more extensive use, they may and should be revised as seems desirable. The use of these grades in the retail sale of canned foods would certainly meet with the hearty approval of consumers and of home economists in particular the country over.

Brands and trade-marks would not become valueless if canned products were labeled according to their grades. The brands and trade-marks would continue to identify products put out by given concerns and would enable consumers to obtain products with the characteristics which tend to give distinction to each well-defined line of goods.

The women who crowd our grocery stores today are more anxious than formerly to learn the quality of the products they buy and to be saved from paying an A grade price for a grade C product. If they pay the grade A price, they want grade A goods. There is a real drive behind this desire because family funds are too limited to let them slip away without making every effort to get value received.

The December 1933 issue of Food Industries carries a letter written by Mr. F. M. Snook, field secretary of the Tri-State Packers Association, Easton, Md., which gives evidence that consumers are not alone in believing that canned foods should be labeled as to grade. Mr. Snook's letter reads as follows:

To the Editor of FOOD INDUSTRIES:

I want to congratulate you on the splendid outline of Senate Bill 1944 which you have in the November issue of FOOD INDUSTRIES. I am sure your readers will more fully understand what the thing is all about and just what changes the bill, if enacted, would make in the present food laws.

I do. however, want to call your attention to your criticism of Sec. 7 (e).

The matter of standards and grades for canned foods and the statement of grades on labels, I realize, is one on which the industry has not yet reached an agreement. In saying this I am fully aware that the real objection to grading and grade labeling which is voiced by certain of the canning industry and some of the distributors is not founded on any belief that standards could not be made applicable for the entire country. On the contrary, back of it all, but kept, of course, in the background, is the fact that quite an embarrassing situatiou would arise if national advertisers were faced with the necessity of stating grades on labels.

The reference you make to a Federal definition of fancy canned peas is unfortunate, because, as a matter of fact, federal definitions and grades of canned foods have been ardently advocated and supported by Tri-State packers and opposed by certain Minnesota canners. I can assure you that Delaware and Maryland are perfectly willing to have their packs graded under the federal definitions, and we don't come out so bad after all.

The idea of different standards for different sections was exploded several years ago. I recall that some of the leading canners of a middle-western State fathered the idea. A definition for grades would necessarily differ, depending on the section of the country in which the commodity was packed. I recall distinctly that one canner went even further and advocated the idea that the definition would have to vary from year to year in the same locality, depending on the quality of the raw product as it came from the field. Of course, what he was trying to do

was to grade the definition and not grade the product.

We have now reached that stage in the development of the canning industry in which we have set up Federal definitions for fancy, extra standard and standard products.

Then we check our products to coincidè as closely as possible with these definitions. If a canner of peas in Delaware packs his peas at the proper stage of maturity and they meet the Federal definition of fancy, then they are fancy peas. If they fail to meet the definition and measure up only to extra standard, then they are extra standard. One of our Maryland canners this fall was awarded a contract for fancy Golden Bantam corn. This corn was fancy because it measured up to the Federal definition for fancy corn. Last year one of the Maryland packers of snap beans was awarded a contract for 10,000 cases of fancy snap beans in competition with New York and Wisconsin packers, because his pack of beans more fully measured up to the Federal definition for fancy beans than those submitted by canners of New York and Wisconsin.

I can assure you, L. V., that there will be no request by southern canners for a lowering of grade standards to fit our goods. On the other hand, we are fully aware that canned foods are not per se fancy because they happened to pe packed in a northern State.

One reason I welcome the opportunity to speak at this hearing is that I may voice the desire of consumers for the protection which they will have if this bill is enacted into law.

The statement has been made that there is no demand for this protection. I believe we need only to look into the method being employed by the opponents of this bill to understand why the public is confused about its value.

May I call your attention to the fact that certain of the opponents are doing everything in their power to muzzle the press and thereby prevent a correction of the misrepresentations of this bill which these opponents are using every means at their disposal to disseminate as widely as possible.

I am asking the privilege of having included in the record the 17 plans listed in the September 18, 1933, issue of the Drug Trade News, as the means Mr. Clinton Robb's organization, the United Manufacturers of Proprietary Medicines, is using to defeat this bill. They are as follows:

THE 17 PLANS

1. Increase the membership of association at once to present a united front in combating the measure.

2. Secure cooperation of newspapers in spreading favorable publicity, particularly papers now carrying advertising for members of the association.

3. Enlisting all manufacturers and wholesalers, including those allied to the trade, and inducing them to place the facts before their customers through salesmen, and in all other possible ways, to secure their cooperative aid.

4. Secure the pledge of manufacturers, wholesalers, advertising agencies and all other interested affiliates to address letters to Senators to secure their promise to vote against the measure.

5. Line up with other organizations, such as Drug Institute, Proprietary Association, National Association of Retail Druggists, and others, to make a mass attack on bill.

6. Appointment by the President of a committee to work in conjunction with Attorney Clinton Robb.

7. Cooperation of every member in forwarding to headquarters newspaper clippings and all available data as basis for bulletins and favorable publicity. 8. Cooperation of every member in doing missionary work in home districts to arouse public to the dangers of the legislation proposed.

9. Carrying to the public by every means available, radio, newspaper, mail, and personal contact, the alarming fact that if the bill is adopted, the public will be deprived of the right of self-diagnosis and self-medication, and would be compelled to secure a physician's prescription for many simple needs.

10. Arrange for conferences between Association Committee and representatives of all other trade associations interested.

11. Enlist the help of carton, tube, bottle, and box manufacturers.

12. Defeat use of ridicule by American Medical Association, proponents of the measure, by replying with ridicule.

13. Convince newspapers of justness of cause and educate public to same effect.

14. Setting up publicity department for dissemination of information. 15. Enlisting aid of Better Business Bureau in various cities.

16. Direct and constant contact with situation at Washington under leadership of Attorney Robb.

17. Pledge of 100 percent cooperation on part of every member of the association present for continued and unremitting activity in every possible direction to defeat measure.

One manufacturer of a patent medicine is carrying on his campaign against the bill by addressing newspaper publishers as follows:

You are about to lose a substantial amount of advertising revenue from food, cosmetic, and drug manufacturers.

Your pocketbook is about to be filched and you will see how if you will personally study, or have your lawyer study for you, the enclosed copy of the Tugwell bill and the two parallel analyses of it. The bill was introduced by two doctors in the Senate and House of Representatives respectively during the last session of Congress.

You publish your paper for profit and as a service to your community. In most virile business organizations the altruistic policies in the final analysis are means to the primary end which is profit. From a profit standpoint_you will quickly see how you will be affected by this bill if it becomes law. From the standpoint of service to the people of your community we ask your careful reading of the enclosed folder entitled "The Economic Necessity and Moral Validity of the Prepared Medicine Business."

We ask you to take an active, aggressive stand against the bill, not as a matter of cooperation to us or other advertisers, but for your own business interests and the best interests of your community. An isolated editorial or two will not suffice in this matter.

1. You need to take an aggressive stand against this measure.

2. You need to bring all the personal pressure you can upon your Senators and Representatives.

3. You need to enlighten and thereby arouse your public against this bill that is calculated to greatly restrict personal rights.

If this bill should become law, we will be forced to cancel immediately every line of advertising. It is our opinion that we would not endeavor to contend with the administration of the unreasonable sections of this bill and that the business would be "Milked" without any advertising or selling

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