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health effects and we do have a procedural impact as prescribed by the legislation.

I think if Congress wanted to change that. that would be something they would have to discuss.

Mr. MESERVE. Can you tell me, is the Public Health Service presently using DDT or any other hard pesticide to control disease vectors in the United States?

Mr. JOHNSON. In the United States?

Mr. MESERVE. Yes.

Mr. JOHNSON. The Public Health Service itself

Mr. MESERVE. Any portion of HEW.

Mr. JOHNSON. I would dare say, if you put it that way, somewhere down the line there is a small bit of pesticides being used because you have many kinds of activities.

This would be on a very small in-house pesticide control operation, but if you mean on a large basis, I believe that this is not the case now, talking in terms of a

Mr. MESERVE. Is it a matter of Department policy that has caused you to substitute other pesticides for DDT, or have you cut back on all the control programs because they are no longer necessary?

Mr. JOHNSON. Well, certainly in terms of the latter statement, we have cut back one major program because of limitations in budgets in which I suspect a large amount of DDT was being used.

I would also say, however, that there has been a changing of philosophy in HEW, certainly, since I came on the scene, at which time we were working very rapidly and very hard at determining what our position should be in the total area of pesticide use.

So this was something in the back of our minds.

Mr. MESERVE. The point I am really driving at is whether the Department has had certain disease control programs which had, until fairly recently, involved the use of hard pesticides?

Mr. JOHNSON. That is correct.

Mr. MESERVE. And whether the Department has made a value judgment that the use of these pesticides may be causing considerable harm to the environment, so it therefore has made a policy decision to find substitute pesticides for use and has, in fact, been able to find adequate substitutes.

Mr. JOHNSON. This is part of the impetus behind the Secretary's study commission, so we would know on a cost-benefit-risk basis just what pesticides we should recommend as a policy.

Mr. MESERVE. But you cannot say at this time that the reason you are no longer using large quantities of DDT is because of a policy determination which led you to find an adequate substitute.

Mr. JOHNSON. I cannot say that at this time.

Senator HART. Gentlemen, in view of the exchanges that we have had, and any testimony or comment you heard this morning, is there anything that you would like to add to the record which might be helpful?

Is there any area we have not touched upon which you think relevant?

Mr. JOHNSON. I can't think of anything Mr. Chairman. I want to emphasize that certainly the basis for this hearing is timely. We are very much concerned with the total ecosystem that man has to live and

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exist in. We are concerned with more than just the effect of any pesticide on man directly but also indirectly.

Secretary Finch has expressd this concern through the charge to the Commission that he has established.

I think for the first time we are going to come up in HEW with a policy that will help us to guide our future destinies and our use of pesticides.

It may not always be exactly what some of the very emotional speakers have said, but certainly I think on balance we have to look at all of the aspects of man. We should not forget and I would like to emphasize that pesticides have been a bountiful benefit to man, and we just want to be sure that when we do this, we use them in such a way that not only are they a benefit of what it takes to sustain man's life, but it is done at a minimal risk in terms of what it might do to his health as well.

And we are working-I want you to know, we are cooperating with you in any way we can to arrive at the kind of policy that will give the American public this kind of assurance.

Senator HART. We appreciate your cooperation and acknowledge it. Together with your help we can develop an understanding and a set of standards which will serve the interests of the people.

I have the feeling, as with a lot of things in Congress, that we are a little bit late. We spent so much time hailing the arrival of DDT as the greatest thing since the invention of the wheel that we were a little slow in recognizing that there were some unfortunate side effects. "Silent Spring" was a great seller, but some of us didn't react very quickly, I'm afraid. I hope we will respond to this quickly. Thank you very much.

If this concludes the testimony to be taken, we will adjourn. (Whereupon, at 3:54 p.m., the committee was adjourned.)

APPENDIX A

LETTERS, STATEMENTS, AND ARTICLES

Hon. PHILIP A. HART

U.S. DEPARTMENT OF THE INTERIOR
Washington, D.C., June 11, 1969.

Chairman, Subcommittee on Energy, Natural Resources, and Environment, Washington, D.C.

DEAR SENATOR HART: On May 19, 1969 I testified before your subcommittee on the effects of pesticides on sport and commercial fisheries.

I have recently received a copy of a resolution from the Mississippi Game and Fish Commission opposing the use of persistent pesticides. I would appreciate your making this resolution a part of the record. An original copy is attached. Sincerely yours,

LESLIE L. GLASGOW,
Assistant Secretary,

Fish and Wildlife, Parks, and Marine Resources.

RESOLUTION OF GAME AND FISH COMMISSION, STATE OF MISSISSIPPI

Jackson, Miss., May 26, 1969. Whereas the Mississippi Game and Fish Commission is vitally concerned about the future of fish and wildlife in the state of Mississippi; and Whereas increasing amounts of pesticides are being found in the waters of the State and in the flesh of the fishes of the State; and

Whereas these increasing amounts are having a detrimental effect on fish and wildlife: Now, therefore be it

Resolved by the Game and Fish Commission, That it does hereby go on record as opposing the use of DDT, Aldrin, Endrin, Chlordane, Lindane, Heptachlor, Dieldrin and Toxaphene; be it further

Resolved That the Game and Fish Commission urges the United States Department of Agriculture, Mississippi Department of Agriculture and the chemical companies to seek diligently for controls for harmful insects that will not be detrimental to fish and wildlife; be it further

Resolved That legislation and/or congressional action be instigated to prohibit or restrict the use of the persistent pesticides by appropriate means; be it further Resolved That in evidence of the concern of the Game and Fish Commission about this matter, certified copies of this resolution be sent to the Governor of the state of Mississippi, Secretary of Agriculture of the United States, Secretary of Interior of the United States, Commissioner of Agriculture of the state of Mississippi, President of Mississippi State University, and each of the United States Senators and Representatives from the state of Mississippi.

Certificate

The undersigned, R. C. Cook, Jr., Chairman of the Mississippi Game and Fish Commission, and Billy Joe Cross, Executive Director of the Mississippi Game and Fish Commission, hereby certify that the foregoing is a true and correct copy of the resolution adopted by said Commission at its meeting held on May 15, 1969.

Witness my signature this 22nd day of May, 1969. [SEAL]

BILLY JOE CROSS, Executive Director.
R. C. Cook, Jr., Chairman.

(187)

Hon. PHILIP A. HART
U.S. Senate

Washington, D.C.

NATIONAL AGRICULTURAL CHEMICALS ASSOCIATION
Washington, D.C., June 11, 1969.

DEAR SENATOR HART: We respectfully suggest that four statements in the Transcript of Proceedings; Hearing to Consider The Effects of Pesticides on Sports and Commercial Fisheries; U.S. Senate Committee on Commerce; Subcommittee on Energy, Natural Resources, and The Environment; May 19, 1969 require clarification.

1. Concerning the cancellation of a registered product, beginning on page 95, line 25 of the Transcript:

In this section of the testimony, there is this statement, ... if there are bad side effects, we [USDA] would cancel the one that had the bad side effects." The Act states: "The Secretary, in accordance with the procedures specified herein, may suspend or cancel the registration of an economic poison whenever it does not appear that the article or its labeling or other material required to be submitted complies with the provisions of this Act." We find no provision in the Act for the concellation of a registered product because a newer pesticide is judged by the USDA to be an alternative and to have less harmful side effects.

2. Concerning DDT residue tolerance in milk, beginning on page 110, line 25 of the Transcript:

In this section of the testimony, there is this statement, "The last of the questions we wanted for the record concern and the DDT residues in milk. Now the Food and Drug permits no DDT residues in milk, as I understand it."

The regulations under the Federal Food, Drug, and Cosmetic Act include a tolerance for DDT in milk in 21 CFR 120.147 c. Residue tolerances of 0.05 part per million in milk for each or any combination of DDT, DDD, and DDE (equivalent to 1.25 ppm on the milk-fat basis) are established.

3. Concerning the review of a petition for a residue tolerance by a committee of outside experts beginning on page 148, line 25 of the Transcript:

It is not clear from the record whether or not Mr. Charles Johnson, Administrator of Consumer Protection and Environmental Health Service, was saying that all petitions for the establisment of a tolerance are reviewed by a committee of outside experts, but this seems to be implied. At one point in this section of the testimony he said, "This is a fixed procedure by and large, and we follow this in most instances."

Under Section 408, (d), (3) of the Pesticides Amendment to the Federal Food, Drug, and Cosmetic Act, referral of a petition to an advisory committee is made at the request of the person filing the petition or on a decision by the Secretary of Health, Education, and Welfare that such a referral is necessary. The evaluation of the petition and the subsequent decisions regarding it are normally made by the Food and Drug Administration.

4. Concerning the persistence and metabolism of DDT, page 3, line 6 of the Transcript:

In the opening remarks this statement was made, "And since few, if any, forms of life can break down the chemical [DDT], it has become increasingly concentrated in those fish toward the end of the Lake's food chain." We wish to point out that the term "persistent" is relative. Under normal residue levels, even the "persistent" organic pesticides in the environment are degraded through physical, chemical, and bio-chemical action. The rate will vary depending on soil type, moisture, temperature, cultivation, light, aerobic or anaerobic conditions, and soil micro-organisms.

Organisms may absorb persistent organic pesticides from their food and environment. Different plants and animals absorb metabolism detoxify, store, and excrete these materials at different rates. The rate of metabolism at different excretion of some pesticides is quite slow.

At normal low levels of in take, a dosage-storage equilibrium will be established. As losses balance intake, the pesticide content of an animal body will remain constant. If intake increases, equilibrium will be established at a higher level and if intake decreases, equilibrium will drop to a lower level. Studies of storage dynamics of DDT in humans have confirmed results from studies on other mammals.

The available evidence indicates that the conception that organic pesticides cannot be broken down in the environment and by micro-organisms and higher plants and animals is erroneous. Dr. Paul Porter, an associate member and consultant to pesticide commissions of the International Union of Pure and Applied Chemistry, has said, "I know of no natural situation where DDT is not degraded."

We appreciate the opportunity to submit these facts and comments in the interest of an accurate record upon which your subcommittee can draw sound conclusions.

Sincerely,

PARKE C. BRINKLEY,

President.

MICHIGAN STATE UNIVERSITY, East Lansing, Mich., June 10, 1969.

Mr. HUGH GALLAGHER,

Senate Commerce Committee,

U.S. Senate, Washington, D.C.

DEAR MR. GALLAGHER: As you requested in our earlier telephone conversation, I am enclosing a copy of our report entitled "Coho Salmon Mortality and DDT in Lake Michigan," and a copy of a news release issued on March 7, 1968.

Our research was initiated in 1967 to evaluate the biological significance of pesticides in salmonids (trout and salmon) in the Great Lakes. Data developed during the first year's work indicates that DDT and possibly other pesticide residues, accumulated in the eggs of adult coho salmon, are toxic to the developing young salmon. The details of our work are given in the above mentioned report.

During 1968 and 1969 we have substantially expanded our research effort to determine the specific action and critical concentrations of pesticides in fish eggs. Although our recent work is not complete our results to the present time tend to substantiate our earlier findings.

Some newspaper accounts and television reports have stated we found DDT killed up to 50 percent of the salmon in Lake Michigan. This is an unfortunate misinterpretation of our statement. To my knowledge pesticide levels in Lake Michigan are not directly harmful to juvenile or adult salmon. However, our results indicate that pesticide residues accumulated in the eggs may be lethal to the developing fry.

Earlier this year, I replied to a query from a Detroit Free Press reporter, by stating that, (1) we had nothing new to add to our statement issued on March 7, 1968 and (2) that I had not said at any time that fish died in Lake Michigan from insecticide poisoning. The latter statement was intended to correct previous reports about salmon mortality in Lake Michigan. I am sure the meaning of the statement was clear to the reporter but it has been misinterpreted as a categorical denial that the mortality of the salmon was due to DDT. (See enclosed testimony by Dr. R. W. Anderson-Hearings of Agriculture Subcommittee on appropriations).

The pesticide problem is very complex and obviously one which cannot be resolved easily. There are very few who would advocate hasty action by legislators or regulatory agencies to unduly restrict the use of specific pesticides. However, research data has been developed over more than ten years which clearly shows DDT and certain other chlorinated hydrocarbon insecticides are serious environmental contaminants which must be strictly regulated to prevent ecological damage. Legislative or regulatory action at this time could hardly be con sidered hasty.

I feel confident that proper regulation of pesticides use can be provided which will not impair our agriculture or our nations health. I feel we are irresponsible if we are willing to gamble the quality of our environment for a slight and temporary economic advantage. We need more research, but more important we must recognize the results of past research and act accordingly.

I am hopeful that this information is of some value to your investigation. Please notify me if I can assist in any other way.

Yours truly,

HOWARD E. JOHNSON,
Assistant Professor.

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