Document pBv536MoYLE4Dm9Od4V55qkoa
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Manufacturing Chemists Association
MINUTES OF MEETING
FOOD, DRUG, AND COSMETIC CHEMICALS COMMITTEE
MCA Conference Room
Washington, D. C.
May 3, 1972
Members Present
T. W. Hanavan, Chairman George Ingle, Vice Chairman T. R. Aalto R. S. Bryant C. H. Goodman (for H. C. Spencer ) C. F. Hagan (A.M.) W. A. Knapp J. A. Korth W. H. Meyer Peter Morison K. E. Mulford P. E. Neiman R. F. Philpitt M. B. Ver Nooy
(for C. P. Carpenter) M. M. Hoover, Secretary
E. I. du Pont de Nemours & Company Monsanto Company Tenneco Chemicals, Inc. Stauffer Chemical Company The Dow Chemical Company Pfizer Inc. Allied Chemical Corporation CPC International, Inc. The Procter & Gamble Company Eastman Chemical Products, Inc. ICI America Inc. Enjay chemical Company Olin Corporation Union Carbide Corporation
MCA Staff
Guests Present
H. A. Birnbaum R. L. Maycock Peggy Walton
3 M Company Shell Chemical Company MCA Staff
Members Absent
F. R. Barron, Jr. Benjamin Borenstein C. P. Carpenter W. E. McCormick J. R. Mennis R. M. Miller A. M. Schnitzer
American Cyanamid Company Hoffman-La Roche, Inc. Union Carbide Corporation B. F. Goodrich Company Merck & CO., Inc. Hercules Inc. Phillips Petroleum Company
IjMAY H
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Members Absent (Cont'd)
H. L. Schulman H. C. Spencer R. G. Troup Samuel Zuckerman
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Mallinckrodt Chemical Works The Dow Chemical Company J. Tj Baker Chemical Company H. Kohnstamm & Company
1. MEETINGS
a. Minutes of Last Meeting - The minutes of the November 17, 1971 meeting were approved as distributed.
b. Next Meeting - It was decided, to hold the next meeting of the committee December 11, 1972 in Washington.
2. PERSONNEL
The chairman reported that Messrs. Ingle and Meyer were elected chairman and vice chairman, respectively, for the two-year term starting June 1, 1972 per the recent letter ballot of the committee.
The secretary read Norman White's letter of March 15 in which he notified MCA of his retirement effective April 1.
3. PROCEDURES
The draft Rules of Organization and Procedure, sent to the com mittee February 8, 1972 were approved.
4. LIAISON ACTIVITIES
a. MCA Board of Directors - Mr. Ingle reported on the February
8 meeting of the Board Liaison Committee for Environmental Quality
and Control.
Minutes of this meeting containing a report on FDCCC
activities were sent to the committee.
The secretary reported that Mr. Ingle was scheduled to make a brief presentation to the full Board at the April 1973 meeting.
b. MCA Ad Hoc Committee on Chemicals Regulation - The chair man reported on the status of the toxic substances control bill, by which manufacturers would be required to file test data on new chemicals before marketing. He said it is unlikely that the bill will become law this year.
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c. MCA Public Relations Department - Mrs. Walton indicated that committee members would be most welcome to assist in manning MCA Consumer Information exhibits, where they would have a good oppor tunity to learn consumer opinions and be helpful in explaining the chemical industry to consumers. Dates for these exhibits are June 6-9 (Denver, General Federation of Women's Clubs), June 26-29 (Detroit, American Home Economics Association), October 9-12 (Denver, National Association of Extension Home Economists), and October 22-25 (Dallas, Girl Scouts of the United States). Anyone wishing to help should contact her.
She reported that the MCA booklet "Food Additives: What They Are, How They Are Used" has been distributed in the amount of 70,000 copies, that 25,000 more have been re-ordered, that this publication is proving most helpful for the purpose for which it is intended, but that there is a need for a question and answer type presentation which would be effective in getting information about food additives to the general public directly.
She also reported that there will be a public relations day immediately preceding the next MCA Semi-Annual Meeting, during which representatives of member companies are to be interviewed. Subject areas such as food additives are to be covered.
d. Grocery Manufacturers of America - The secretary reported that GMA has set up groups to work with the U. S. delegates to the FAO/WHO codex Alimentarius Commission and its subsidiary bodies.
e. International Union of Pure and Applied Chemistry - The secretary reported that comments on the IUPAC proposed specifica tions for dispersion solvents have been received from ten companies, and that they will be forwarded.
f. National Academy of Sciences - The secretary reported that the Industry Committee of the NAS Food Protection Committee has been enlarged, that it has been renamed the Industry Council, that it is to serve the NAS Food and Nutrition Board rather than just the Food Protection Committee, and that Mr. Meyer has been appointed a member of this council.
g. Pharmaceutical Manufacturers Association - Dr. Aalto re ported that the PMA draft Good Manufacturing Practice regulations for bulk drugs is not yet available, and suggested a chemical industry review of this document before it is released.
h. United Nations - The secretary reviewed his FAO/WHO report sent to the committee April 20. He added that comments from Tenneco re additives in soft drinks were sent to the U. S. delegate to the
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Codex Committee on Food Additives April 24, and that the next meeting of the Codex Alimentarius Commission will he held in November.
With regard to the WHO paper on Estimation of the Intake of Food Additives, Mr. Meyer reported that he had met with the U. S. delegate to the Codex Committee on Food Additives concerning this paper, at which time he recommended that the information in it be used for screening purposes only, that any restrictions on the use of food additives due to apparent exceeding of the Acceptable Daily Intake be based on more sophisticated means for estimating intake, and that differences in consumption patterns from country to country be prop erly taken into account. The committee recommended that a letter be sent to the U. S. delegate stating that this represents MCA's position.
With regard to the General Principles for the Use of Food Addi
tives, also on the agenda for the next meeting of the Codex Committee
on Food Additives, Mr. Meyer referred to the proposals that food
additives not be _paxmitted if_they cause a subgiantial redncblon in
the nutritive va1ne of a food, or if the desired effect can be ob
tained by other manufacturing practices which are economically and
technologically satisfactory. The committee recommended that reasons
why these prohibitions should not be approved without appropriate
qualification be advanced at the next CCFA meeting. It was pointed
out that the first proposal above is directed at flour treatment
\
agents.
i. U. S, Congress - The secretary reported on the status of the bills which have been sent to the committee since last October. No MCA action on any of these bills was recommended.
j. U. S, Department of Agriculture - Mr, Morison reported on the realignment of USDA's Meat and Poultry Inspection Program. Information concerning this was sent to the committee April 24.
k. U.S. Department of HEW (FDA) - The chairman called atten tion to three recent Federal Register notices re Polychlorinated Biphenyls (3/18/72 F.R.), Cosmetics (4/11/72 F.R.), and Proposed Procedures for Affirmation and Determination of GRAS and Food Addi tive Status (3/25/72 F.R.). No MCA action was recommended with respect to the first two. With respect to the latter, it was agreed that MCA should comment by the deadline of May 24, and that Messrs. Hanavan, Hagan, Ingle, and Meyer would draft MCA comments.
The chairman also referred the committee's attention to two articles in the April 24 issue of Food Chemical News: one on "post sanction" letters (page 3), and one on food additive safety require ments other than toxicity (pages 21-22). Copies of these two articles were distributed at the meeting.
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83-5 5. OTHER
a. Good Manufacturing Practice Regulations - Mr. Bryant pro posed that the committee draft GMP regulations for food chemicals. It was recalled that the committee had tabled at its May 1971 meeting the drafting of these regulations for both food chemicals and bulk drugs, that the most recent GMP regulations for drugs promulgated by FDA were limited to finished pharmaceuticals, and that the GMP regulations for human foods which appeared in the April 16, 1969 Federal Register contained no blanket exemption for food chemicals as recommended by MCA. It was decided that the com mittee should continue to follow developments in this area, but do nothing beyond this now.
M. M, Hoover, Secretary MMH:gr May 4, 1972 Distribution "A" cc: Board Liaison Committee-Environment
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Betty Rae Stevick
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& <y^
Eating, one of the great Amer was added try salt because it helped
ican pastimes, is suddenly getting prevent the /occurrence of goiters.
less pleasurable. The food available- If you preferred to get your iodine
in supermarkets used to make us requirement naturally through fish
glad to be in this country. The or seaweed, plain salt was always
abundant array of fresh looking, availableyNow, the story is different
perfectly formed fruits and vege with salt, and it is typical of what is
tables, the red meats, the great happening throughout the food indus- `
variety of all kinds of foodstuffs try. New chemicals are being added.
available is the result of great ad One brand of salt has as many as five `
vances in food technology. But now ingredients listed on the label: salt,
we are beginning to wonder potassium iodide, yellow prussiate of
whether we are overdoing our soda, sodium aluminum silicate and
chemical engineering of foods. dextrose. You cannot' find salt
Thiabendazole, ethoxyquin and without at Jeast one additive be
o'phenylphenate maintain fresh yond potassium iodide in most
ness and retard spoilage of oranges supermarkets.
and apples; sodium nitrite keeps Since the' public is not being
meat looking red; yellow prussiate given the opportunity to choose
of soda and sodium aluminum sili but is forced to buy foods contain
cate help salt pour. Innumerable ing. chemicals it knows nothing
additives make new foods out of about,, people are beginning to
soybeans and cereal grains. Bea have second thoughts about put
trice Trum Hunter points out in ting their health into the hands
Consumer Beware! that "nearlyl of food manufacturers who axe
60 chemicals may be present in ~a| proving to be unreliable juihoiir_
1loaf of bread without label dec-1 4iS-
laration."
New knowledge in the field of
Against all this as a background, molecular biology is making us
the rising statistics in cancer and aware that chemicals can damage
heart disease stand in stark contrast. our cells in two important ways:
The discovery that some food they can poison our cells by af
chemicals cause cancer leads to the fecting the non-genetic material,
suspicion that others are also haz and they can alter the genetic
ardous. The refining of flour and material of our cells. This genetic
sugar has_been_related to the in alteration may result in cancer,
cidence of cancer.
deformed embryos and hereditary
The really disturbing fact is that diseases.
we cannot get away from these
Damage to the genetic material
chemicals as food processing is produces, for all practical purposes,
developing now. We used to be irreversible effects. Although re-
grateful that potassium iodide
Mrs.- Stevick, who completed
her M.S. in microbiology at George
Washington University recently, is a
member of the Arlington <Va.) Branch.
pair of damaged genes may take place in the laboratory, an ounce of prevention is still worth a- pound of cure. Theoretically, in some instances, one molecule of a potent chemical agent could cause genetic damage, and cells may store this kind of. damage so that it adds up. Thus, there is really no insignificant dose of such chemicals. On the other hand, chemicals which affect only the non-genetic materia! of a cell
may be toxic at one level of con centration and non-toxic at a lower level, or their, effects mav be re versible when the ' offending agent is. removed.
The `public is not protected by | law from food additives that alter! genetic material. As it stands today, the Food, Drug and Cos metic Act restricts food additives in two ways: it totally bans any additives which have been found to produce cancer in man or ani mals, and it limits the amounts of toxic additives according to toler ance levels. Cydamates, the arti ficial sweeteners, illustrate the restriction by which carcinogens, or cancer-causing agents are ban ned. Sodium' nitrite is an example of food additives which are limited according to amount. Nitrite is added to meat to "fix" a red color
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(as in ground meats), for "curing" clause of the Food and Drug Act excessive and illegal amounts of purposes (such as in ham or bacon), is that jt_ restricts a chemical only additives?
and to protect against botulism. after it has been found to cause In view of the accumulating evi The use of sodium nitrite seri ancer. It may take years to de dence of inadequate safety, public
ously challenges the adequacy of termine whether a chemical clamor is mounting for preventive
both these restrictions. First of all, causes cancer, using laboratory measures to be taken to protect the
its use demonstrates the weak animals. That period may be food supply. FTen. Gaylord Nelson
legal protection given the public shortened to a matter qL. days .oc. is introducing a bill in Congress
against the toxic aspects of food , weeks _for most carcinogens if we which would restrict food additives
additives, both from the point -of >"make use of the laboratory to necessary usage and totally ban
view of necessity of usage and en- ^: techniques and principles which not only carcinogens, but also muta
forcement of legal limits on amounts " are being developed to study gens. Now that we know that there
put into food. According to testimony > . mutation, the alteration of genetic is not only the threat of toxicity
in a House subcommittee hearing * material. Most, and perhaps all, and cancer from the use of chemi
chaired by L. H. Fountain, Demo- carcinogens are mutagens, chemi cals in our food, but also that some
cratic congressman from North Caro-V cals which alter genetic material. chemicals can alter genetic ma
lina, death .and injury have occur-1 Many mutagens are carcinogens. terial and cause mutation, we can
red from yeitdssive nitrite in process This is a very important relation make use of that knowledge in
sed meats. It was reported that a^r ship, because it . makes rapid formulating a legal concept of food
small margin of safety separates screening of carcinogens possible. safety that is directly concerned
safe from hazardous concentrations of It takes only days or weeks-with the with the protection of the con
nitrite. Children who eat many hot
sumer and the offering of guide
dogs, bologna and other processed mine in the laboratory whether a lines to the producer.
meats are particularly susceptible. chemical causes mutation. The The more informed the public
sOne three-year-old boy died after eat-< new knowledge we are accumu is on these matters the more it can
ting a raw hot dog which contained! lating about mutation is significant put pressure on the government
(three to five times the legal limit.' not only because mutation leads to and industry to update its ideas
Dangerously excessive and fatal harmful effects but also because of and testing of food additive safety.
amounts of sodium nitrite (up to dthe new techniques it makes possible f More research is needed to refine
15 times the permissible level) for rapid detection of harmful agents.1 the mutagenicity tests in existence
have been found in smoked sal Some of the undesirable effects and to develop new ones.
mon, hot dogs and processed of mutation are embryo damage, President Nixon is supporting an
meats. The present permitted genetic disease or cancer. Most intensive campaign to find a cure
levels could be greatly reduced mutations are harmful and result for cancer. It would seem that pre
if "cosmetic" uses of nitrite were in a lowered resistance to disease, ventive measures against consump
forbidden and only enough of it a lowered life span, increased in tion of known and suspected car
were used to preserve meat and fertility, and general physiological cinogens would be an important
fish products in a wholesome con weakness. Because man is geneti step in the war against cancer. By
dition.
cally complex, there are many testing food additives for their
The inadequacy of the restriction possibilities for mutation. There mutagenicity, and by enlarging our
of carcinogens by the Food, Drug are at least 1,500 diseases which legal concept of hazardous food
and Cosmetic Act is also illustrated are considered to be of genetic additives to include those which
by the use of sodium nitrite. Some origin. Sickle cell anemia and cause damage to genetic material,
medical researchers, including Dr. diabetes are two examples.
we may strike a blow against many
William Lijinsky of the University Mutation is becoming increas diseases caused by genetic damage,
of Nebraska Medical Center, have., ingly important to us. Because including cancer.
accused sodium nitrite flLJtBSiihSiU death rates due to parasitic and We can take definite action as
contributing to a needlessly large bacterial diseases have decreased, individuals by becoming well-in
cancer toll among Americans. genetic disease is being found in formed and supporting appropriate
Nitrite is one of the two ingre relatively more people. Once a legislation and organizations. Letters
dients that combine to form mutation is introduced it may re may be sent to the following:
nitrosamines, which are powerful main in the genetic material for as (1) to your own senators and to 5en.
cancer-causing agents. Dr. Ujin- many as 40 generations. Genetic Gaylord Nelson, 4040 Senate Office
sky reported in a recent issue of the diseases have been occurring at Building, Washington, D.C. 20510,
journal Tetrahedron that there is a about the same rate for probably -
possibility nitrosamines can be thousands of years, but we are
formed in the human stomach only beginning to become aware
when there is a diet containing of them collectively. Jt js possible
nitrites and amino acids, which we may have an increase in genetic
are found in blood and muscle.
disease if we continue polluting the
A weakness of the cancer environment, which includes our
food.
More and more, the public is
asking these two questions about
food additives: Are the chemicals
necessary for the wholesomeness of
the food to which they are being
added? Does the government
have adequate resources to main
tain surveillance of the food manu
facturers who process food with
12 AAUW JOURNAL/APRIL 1972
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in support of legislation Sen. Nelson is drafting which would restrict food additives to necessary usage, ban mutagens and teratogens (chemicals which cause- embryo damage) as well as carcinogens, eliminate the GRAS list (food additives generally recognized as safe), and expand FDA's authority, requiring more testing of drugs and tighter rules of inspection.
(2) to Charles C. Edwards, M.D., Commissioner, Food and Drug Administration, 5600 Fishers Lane, Rockville, Md. 20854, to support the requirement that all ingredients be listed on the labels of processed foods, even when a Standard of
Identity has been established. (3) to your own congressman to sup
port bill HR8670, introduced by Rep. Rosenthal, which would amend the federal Food, Drug and Cos metic Act to require the labels on all foods to disclose each of their ingredients.
(4) to your senators to support Food Labeling Bill S. 3083 intro duced in January by Senators Moss and Hartke. This is the most com prehensive of bills to amend the federal Food, Drug and Cosmetic
Act. (5) for membership in such groups
as the Federation of Homemakers, a non-profit lobbying organization concerned about food legislation and consumer protection. Applications for membership may be sent to Mrs. Gordon B. Desmond, President,
Federation of Homemakers, 927 N. Stuart St., Arlington, Va. 22203. (Member--$5.00, sponsor--$10.00).
Another action which we can all take is to learn the essentials of good nutrition and then buy the best available basic foods for sup plying our nutritional needs. There are so many conflicting ideas about nutrition that it is perhaps wise to look at all of them with an open mind and adopt or reject them ac cording to one's own knowledge of self and family.
We are living in an era when not only new scientific knowledge is being made available to us, but we are falling heir to wisdom ac cumulated throughout the ages by
many cultures. Both of these sources of knowledge need to be correlated in the field of nutrition before the sqtfrre of ancient nutritional wis dom is lost to us through neglect to retrieve it as modernization com pletes its effect on society.
One of the most recent contri butions that science has made to the field of nutrition is the know ledge that some food chemicals, both artificially produced and naturally occurring, can cause mu tation of the cells of our body and lead to cancer, genetic disease, embryo damage and possibly aging. We need to apply this know ledge to monitor the production and distribution of our foods. There is much money invested in food pro cessing, and the tendency has been to identify processed, refined and chemically treated and produced foods with progress. In fact, the continued consumption of such foodstuffs may lead to our physical degeneration as a nation. In our haste to share our technological knowledge with other nations to help them develop, and in their eagerness to reach our standard of living, we may pass on not only our scientific knowledge of nu trition and food safety, but our great talent for manipulating chemi cals and food for the profit of the few at the expense of the masses in the name of feeding the hungry of the world. We must study carefully where chemicals are actually needed in food for the benefit of humanity.
A studied look at the total food picture and the specific point where we enter into it as individuals would seem to be compatible with the interests of AAUW, since the proper functioning of our bodies is so necessary to our mental and emo tional health, which, in turn, affect our intellectual growth.
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' /#
FOOD
Editor*; Louis Rothschild, Jr,; Raymond Galant April 24, 1972
Subscription Manager: Natalie Pargas
FDA DECIDES TO END USE OF "POST-SANCTION" LETTERS
The Food and Drug Administration has decided to eliminate the use of so-called "post-sanction" letters permitting minute-levels of indirect-additives in food from packaging uses.
The decision to discontinue the practice came as a result of an industry dispute in which a company challenged the legality of a i informal approval held by another only to find out that the "post-sanction" letter was, in fact, valid.
*The use of the letters has been in dispute at FDA "for some time, but th new controversy resulted in a reappraisal of the practice. The letters, which are 1 sometimes used to inform inquirers that they have "no food additive problem," 1 based on the minute or trace levels of migration expected, will notbe r voked | under the new policy.
A New Subpart under ^121 to Be Used to List Minor Migrants
However, FDA-ers will now require a listing under a new 121 subpart for "insigni ficant" levels of migrants from food packaging materials. Data required for this type of listing are not expected to be as extensive as now expected from firms who go through the Food Additive Petition process to clear indirect additives with problems of toxicity.
Current feeling at FDA is that substances fall into only three categories: (1) Prior sanctions; (2) "Generallylfecognized as safe;" and (3) Regulated additives.
The new listings will bring these indirect additives into regulated status, and, _once published, -unless-protected by-patents, like other Food Additives, can be manufactured by any company.
The current dispute erupted from a competitive battle. One firm held a letter; the other did not. FDA decided the "post-sanction" letter to one resulted in ted a competitive advantage.
o'"
The new approach is expected to put all companies on an equal footing.
es
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.1 24, 1972
1 ft"
Page 21 FOOD CHEMICAL NEWS
In a letter to Pfizer, FDA listed a number of requests for additional data, including some on the validation of the manufacturing process plus others concerned with analysis of intermediates in the process and the finished product, with emphasis on polynuclear aromatics such as benzo(a)pyrene.
After receipt of the additional data, FDA wrote, "we then can comment on the need for a suitable speciiication test on the final citric acid to preclude the presence of carcinogenic PNA's."
If after review of the supplemental data, FDA said, "we can agree that the Pfizer product, with any needed specification test, complies with the requirements of the Food Chemicals Codex for food-grade quality, the submission can be considered as a petition for GRAS affirmation ..." The FDA letter pointed out that under tie procedure, a 60-day period for interested persons to review the petition and/or file comments will be permitted.
a-
FOOD ADDITIVE REQUIREMENTS REACH BEYOND TOXICITY, HUTT SAYS
The Food and Drug Administration is ready to reach beyond toxicity of food addi tives to other safety questions under the Food Additives Amendment.
This became clear in a letter from Gerald F. Meyer, Director of FDA's Office of Legislative Services, to Chairman Rogers (D-Fla.) of the Public Health and Environ ment subcommittee of the House Interstate Committee.
Rogers had expressed concern over the potential hazard to children from the use of pull-off top cans. In response, Meyer explained that the agency can exercise
legal jurisdiction over problems of this type either through the Food Additives Amendment or through the child safety provisions of the Federal Hazardous Sub stances Act.
*"7
Meyer's position was apparently based on an opinion from General Counsel Peter Barton Hutt in a memorandum to Sam Fine, Associate Commissioner for Compliance, reversing the draft of a letter originally prepared for Rogers that indicated FDA had no jurisdiction over pull-off top cans.
In the recent oven bag matter, Hutt wrote, "we took the legal position that the safety requirements of the Food Additives Amendment reach beyond toxicity and include other aspects of consumer safety" (See FOOD CHEMICAL NEWS, Feb. 28, Page 4). Hutt continued:
"We could also take the same position here. We could, for example, issue a regulation under Section 409 in effect withdrawing food additive approval with respect to any pulloff tab can intended for food use unless_.it met specific safety criteria established in the regulation."
> ''
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Page 22 April 24, 1972
FOOD CHEMICAL NEWS
Meyer, in his letter to Rogers, similarly pointed out that in the oven ban contro versy, "we were prepared to take action against the products if necessary under the safety requirements contained ini the Food Additives Amendment,"
He said the same could be done, with the pull-off top cans, but "it appears to us more appropriate to proceed instead under.the provisions of the Federal __ Hazardous Substances Act which cover any `article for use_by children.1-.which represents a mechaai6a4-ha-zar<sL"
Meyer told Rogers that the Bureau of Product Safety is working with industry to correct the can top design to eliminate the hazard, and he outlined some of the progress being made.
SUPREME COURT RULING, OTHER ISSUES IMPACT PESTICIDES PROGRAMS
A Supreme Court ruling April 19 that esthetic and environmental well being are justifiable causes for lawsuits against the government appeared to solidify recent gains of environmental groups.
The ruling came in a week of many other developments regarding pesticides regu lations .
Justice Potter Stewart wrote that while the Sierra Club could not sue simply or the basis of its experience and concern, an aggrieved hiker or other individual could sue on the basis that esthetic and environmental well-being "are important ingre dients in the quality of life in our society."
The suit involved the Sierra Club's attempt to stop the building of a Walt Disney resort complex.
The incursion of columnist Jack Anderson into pesticides discussions with an April 15 column roasting the Environmental Protection Agency's "suppression" of a tough report on mercury wag' another development affecting pesticides regulation.
Assistant EPA Administrator David Dominick circulated a memo forbidding the giving of either of two study reports on mercury to anyone outside the agency, but columnist Anderson apparently was able to obtain a report resulting from a study headed by Victor Lambou, Suppressed also was a report by an internal study group headed by Dr, O. Garth Fitzhugh, who retired April 6 from EPA.
Dominick was unavailable for comment on either of the reports, which were the basis for EPA's recent cancellation and suspension of various mercury products (See FOOD CHEMICAL NEWS, March 2 7, Page 37).
Anderson quoted the Lambou report to the effect that even if all discharges into
the environment were "suddenly and miraculously stopped, the residual already
produced by past activities, if not removed or permanently stabilized, will present
a mercury problem for years to come."
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