' . AN INTERVIEW WITH DR. EDWARD LAWRENCE GRIFFIN • \ I I' sb, ... Would you teJl :.:c ::;o:::eth-Lnc about :yoc:.' c2xee1' and JOur e2xl~/ days? I unde1•r_;t2ncl :'.,'OU we::-',t with the :Jenartrn12nt in 1~113. Dr. Griffin: I had an appoj_nt:,cnt a.s an assistant c'.181.:·_st =·.n 1913, ,·ror::inc in the B'...1rea,u e,f ''.\1er: is try on the ere:':: l'Ce~~ent of V1e Insecti- cide Act of 110. I rer:ort::::d for 11ork c,n June 16., I be1ie\re it uas, 19lj. The ap:9otnti1,ent said to report to Dr. AlsbcrG. I SG~GeGtcd to Dr. HaywooG that I go over ~ncl report to Dr. AlGbcr~ ~nd Dr. HayN~od'c reply ,-ras t'.1at tile; first thing is to c;et your name on the p:.yToll. 1 ;,Irs . Whitaker: Well, did yo~ cct to see Dr. Alsbe~G? Dr. Griffin: No., I never did sec Dr. .'\ls berg. ~.:c ·.!C TC .mrki ng then in t:. 1 laboratory at tl~c bc.r:lc:. er:d of "'.:;hE=: oJ.c.1 E,,·renu of CllPr:~GL':/ 1)1 ~lrJ.lng. The n,~w 1abor:-,.to:.•1t=;:::; '1:hjch v:erf3 being c.w:~Jt .for in2er.t:~c:;_c:c 1•;ort. v;ere in t:·1c 01.l.ve Build::tnr, wl:.ici: ,ms next s01J.th of the laboratories :Col' o,bou t six or eir,ht · ;o:1t~1::;, as I recall. The the lead ars e!w."ce, Paris r;reen and Bordcexx mixture. T:1ose 'Jere the ones tho.t ':tere 1n large 1Jse us :Lnsecti.cides. I worked on Bordeaux ··.:::xL PC':, and a counlc of' ti:e other new c~e:·:,:' ,-:: ts 0 C. ·who ca!'ne in about the same time I did 1·1erc working on Paris green and lead arsenates. After a short time,. however, we began to get more disinfecti=mts and I 1'.'ent over to the dis­ infectant field 8ince my particular line had been organic chemistry. For several years I s:oent :T'"1ch of my time on coal-tar disinfectants, hypochlorites, and pine oil disin­ fectants. I ~adc a considerajle study of methods of analysis for coal-tar dininfcctants. Also I Lade a considerable study of pine oils. At one time I r.1ade a triu through the pine oil '' production areas, from Virginia dm·m t:1e Atlantic coast and across the Gulf coast as far as Elizabeth, Louisiana, studying both the distructive distiJ.lation pine oil and the steam dis- tillation pine oil. I don't know ·what . do you want to go any farther on that or not? Mrs. Whitaker: Yes. Did you feel, even though this v:as before you were in­ volved with adr,1inistrati ve work, that disinfectants belonged under the control of the Insecticide Act? Dr. Griffin: It was certainly accepted in the Denarti.icnt that they Hero t1.nder the Insecticide Act when I ,;1ent to 'i'mrk at it. It was not fully accepted among the manufacturers and there were a nur1ber of cases where it 1,•,as contested. Howe7er, there was one Cc.,Se that we lost on that but in general tre Non the cases. ·---------------------- 3 Mrs. Whitaker: Do you remember the details of the case that you lost? Dr. Griffin: I was not directly concerned in the one that we lost and at this time I can't go into detail. Mrs. Whitaker: Dr. Haywood's feelings were a little uncertain about disin­ fectants in the first two years of his chairmanship of the Board but then he championed the control of them quite ada­ mently after that, with the same kind of dedication that he displayed toward the agricultural insecticides. Do you think that his interests were primarily with agricultural insecticides? Dr. Griffin: They definitely were. However, he certainly encouraged me to go ahead with the things that I was doing. Of course, I did not work directly under Dr. Haywood. I worked under Dr. McDonnell. He was the chief of the chemical laboratory. Mrs. Whitaker: That was Dr. c. C. McDonnell? Dr. Griffin: Yes. LL Mrs. Whitaker: r Tell me something about Dr. Haywood. There are so few pictures available of him. Dr. Griffin: Haywood was very tall., slim., he walked with a little bit of a gangling ~ait. He was inclined to be very enthusiastic about the things that he was working Hith. He was a man who certainly 1-mrked to help the .nen ti1at were under 11:'..:rn. He was the kind of chief that one liked to have. Of course, Dr. Haywood felt that if he wanted to cuss some of his oeoole out that was all right but if somebody else did, that was something else yet again. Mrs. Whitaker: Did he work directly with the inspectors, also? Dr. Griffin: He didn 1 t work directly with the insnectcrs. Mr. Shibley was in charge of the j_ns1)ectors. Mr. Shibley handled that Dart of the thing. Mrs . Whi talrn r : Mr. Shibley's initials were . . . ? Dr. Griffin: James G. 5 Mrs. Whitaker: And he had been with the Board almost from its inception? Dr. Griffin: As far as I know, from its inception. Mrs. Whitaker: As far as you know, was there any dispute between Marion Dorset and Dr. Haywood about the matter of disinfectants? Dr. Griffin: can't tell you that. know that he and Dr. Dorset didn't I I I always agree but that's normal. Mrs. Whitaker: I After Dr. Dorset resigned from the Board, saying that he wanted to devote most of his time to research and Haywood took his place as chairman of the Board, did Haywood work well with the other Board members? Dr. Griffin: As far as I could observe, they got along reasonably well. There were no serious squabbles. I don't think they always agreed but then . . . Mrs. Whitaker: He comes through very strong in the correspondence. I have noticed that rie uight have been a li ttlc domineering in his relations wi t~1 the other Board nierr1bers 2nd generally got his way. Dr. Griffin: Well, he was, of course, Chairman of the Board and he, I tl1ink, expected to do things his way. Mrs. Whitaker-: And he was an able cher~is t as well 2,s an adminis tra tor . . Dr. Griffin: I think he was. He ne ·,er did any cher,,ical work during the time that I was there. Mrs. Whitaker: Did your reports as a chemist in the early period go to Haywood? What 1·Jas the procedure when a samD le came ir-i to the Board, was it assigned to one of the Bureaus? Dr. Griffin: It was assigned first to the chemical laboratory. Dr. McDonnell was in charge of the chemical laboratory and he would ta%.e it and assign it to one of the cr1en1is ts and the chemist .. ,rould analyze it an6 then the report of the anaJ.ysis, together \·li th the samDle, would be subrr;i tted to the other bureac,; that might be interested. If it was an insecticide, it would go to Dr. Quaintance. If it was for use on animals, it woulcl 7 go to Dr. Emery during the time that I ·.-m.s there or if it r• was plant disease it would go to Dr. W3.ite and they would look at it fror.1 ti1eir standpoint and then the reports would come back to the Board. There would be charges drawn if necessary. Those charges would go to the Board which held meetings, oh, I guess, about once a week, maybe oftener. Mrs. Whitaker: Where did they hold the meetings? The r,j_nutes do not indicate. Dr. Griffin: They were held in the Board Room on the first floor of the Olive Building. Then the Board would decide what action to take. Mrs. Whitaker: During the teens, before the 1920 1 s, in that period, what \·,:ere the relations with the manufacturers? Did you deal directly with the producers of any of these products? Dr. Griffin: Oh, yes. If charges were brought, they were never sent to the solicitor's office until after they had been discussed with the manufacturer. In the early days, I think that Dr. Haywood did most of the discussion with rnanufacturers. Later, j_t came to Dr. !,icDonnell's office. And Dr. Haywood's reJ.ations with manufac ture1.~s "\vere very good. ::-i:e attended their annual ueetings pretty recularly arid was_, in get1eral, quite fi•:Lendly. 8 Mrs. Whitaker: When the association of' insecticide manufacturers formed in 1914, the p-ublished reports ind.icate that Dr. Haywood i·1as charged with being arbitrary a.nd perhaps r:1ore harsh with the leading n,anufacturers than he was vri th some of the s,:1aller businessmen. Do you think there was any basis for the charges that were made against hi~? Dr. Griffin: No. At least as f'ar as I know there ·was no basis for it. Of course, in an enforcement thing you always try to get the things that are going to affect the , ost people and the 1 larger manufacturers r;~ade the products which affected more neople so that nor~ally you would hit the larger 3anufacturers more than you WQUld the smaller ones. But I don't think there was any intention to pick on the larger manufacturers. Mrs. Whitaker: Under Wilson, President vJj_lson, and Ser.retary Houston, was there any change that you could obser'JC on the working level in what your assignments were? Dr. Griffin: No, as far as tr1e workj_ng level was concerned i t made no difference who was secretary, functions went on. There were enough layers between us and the Secreta:c~r that we were sri1elded somewhat. I can't say that I knew e.nything in the enforcernent of the Insccti2id2 Act which was affec~ed by political 1nter8sts. Mrs . Whitaker : Your work was, before the 1930' s, devoted mostly to the chemical aspect and analytical wor1(? Dr. Griffin: Analytical and research. I got my Ph.D. in that period. I:Irs . Whi take :c: That was in 1 2.3, I believe. The depa1~t::-,ent evidently en­ couraged young cheLlists to go ahead with their work. I notice that even Dr. Hayvrood got his M.D. afte::- he came with the departr:1ent. Dr. Griffin: Oh, yes, they encouraged it. I was able to use my research for my thesis. That is the only thing that they did for E1e. The classwork was done out of hours. Mrs. Whitaker: Back again to disinfectants. Were you involved in the lndustry disnute over whether or not the phenol coefficient was to be placed on the labels? Dr. Griffin: I wasn 1 t involved ~n the argument but I did do some bacteri­ ological work. I had a bacteriology ~incr and I have ru~ many phenol coefficients. 10 Mrs . Whi talrn r : During the 1920 1 s, then, calcjum arsenate became one of the target insecticides . . . Dr. Griffin: Well, calcium arscnates were used an awful lot during the 1920 1 s. Mrs, Whitaker: Did you know Dr. 3. R. Coad? Dr. Griffin: Dr. Coad? The name is familiar but I didn't know hiM ~ersonally. Mrs. Whitaker: Haywood held a rather tight rein on the Board, then, until 1927? Was he living at the tin;e the Food, Drug., and Insecticide Administration was formed and did he 11.ave a function within that administration? Dr. Griffin: Yes, he was livin.e;. We remained j_n the Food, Drug, and Insecti­ cide Administration and he carried out the sac'le functions in that outfit. As a matter of fact, when they broke uu, the research part of the groun, which he had had charce of, went to . . . let's see, where did it go . it went to the Bureau of Che:x;__ stry, I bel5eve, o.nd tl1ere was a cons:Lderable fuss over who was ~o go where. I had a chance to go with 11 the research but I decided to stay with tl1e regulatory. I remember Dr. Sld.nner had talked to me about going over there and Hayv10od got quite peeved because Dr. Skinner tried to get me to go. Mrs. Whitaker: Dr. Skinner had been with the department when Haywood came there as a yotmg nan, I believe, and Haywood had worked some with him on arsenic. Dr. Griffin: Well, Skinner and Haywood were, I think, good friends but they would get ·f)eeved with one another now and then. Mrs. Whitaker: There were a number of amendments proposed, one, in particular, in 1916 b;y Senator Wadsworth, I believe., to require the phenol coefficient to be placed on the labels and those amendments never really got off the ground. Dr. Griffin: No, I don't think that it was really a very good amendment because phenol coefficients would give the idea that the nroduct had certain s tren;th as compared with rJhenol against all sorts of bactci~ia. Actually as you lcnou a phenol coef'fic:..ent was only run 2..e;ainst B. Typhosus and its effectiveness ac;ainst other organis 1 ::s :-.1:J.r;llt be, and frequently was, quite dj.fferent from what it '.-.re.c aD:ainst tvnhoid so tlw.t I think that ohenol ~ ~- ~ -- 12 coefficients 1,:ere ":ore !;iis leading than j"nforma ti ve. Mrs. Whitaker: Both Food and Dn1e; and the Insecticide Board assumed respon­ sibility toward disinfectants and I have not been able to find any for:i2.l arrangement betweerc t:1e t':m agencies. Dr. Griffin: The general arransereent was that anything which was used on or in livinr bodies was Food and Drue. If it was used on or ~ n inan:L· 0,te riateria1s it ,,ms ours. 1 Mrs. Whitaker: Did that condition exist fros the earl~cst days? I notice that there were sor,;e cases where both Food and Drug and In­ secticide brought charges against a prod~ct. Dr. Griffin: So far as I kno:·: ~~ t ,ms ahmys a fact. He never triec. to go into the use oc~ the body. At one t-1:·.,e I was picked to give a presc~tation before the Secretary of Agriculture, enforcing the Insa~tic~Je. ct. And I c~~s a dicserta~ion • +­ on lv and +' vOC .,,...., ,~ 7., - ',_..) L .i. _t.,.'' question that - 13 r tration was foi~r.'.cd, you chose to st2.y 1::it:n thec1. As fa:c as you lme'd the tine, what ~as the ~hilosophy in the re- organizati.on? D:r. Griffin: Well, it was to get the regulatory and the research separated. It was felt ~.:;hat . . . actually the rec;ulatory was so,.::eti'."Jes at loggerheads 1:\"i t:1 the research and of ccurse there \'Jere : 1 an:r tines tht~ t ti:o regu_;_atory is 2 t .1.oc;c;erheads wt th ti1e people in the Dcunrt~ent of Agric0lture that were goinc out and making reco~Jendations tc fa~1ers. It wasn't infrequent that we found Je,'.1:'t.n~s beinr; recom::,ended to farmers which we felt were not su:Ltable for such use, so that to prevent o., conflict of interest it was better to have them separated. l ' Mrs. Whitaker: Haywood, in his early years., was very :,uch in favor of research, in fact, wantE',d to rr-:anufac ture disinfectants. Were you. in ·101 ved in his project to set up machinery ~o produce insecticides under manufacturing conditions? Dr. Griffin: Well, to a certain extent, yes. AlonG about the time of the first world 1.1:;.r, the gypsy r oti1 was attr:tcl<:.ing trees in llei1 1 England and i -t i:Tas killing off a J.ot of 1·:oodland. They had been getting a tarry substance fro·, Ger'..any for tree banding 14 . and it was not available in this country. One of' my jobs was to make a product which vms sin,ilar to the German product that had been ir:iDO 1~ted so that it would be available for tree banding to ~::.eep the gypsy moths fror:, climbing the trees. The gyusy moth apparently was hatched out on the ground or below the trun1::. of the tree and c lirnbed UIJ the tree and took the leaves off. irnd I 1:1ade some of the stuff', you' 11 see one of my articles on tree banding materials in there. We had a soap mixinc; uachine in the building and I made up a couple of tons of that stuff at one tiue, tarry stuff, and another thing t:1at ':!e worked on at about that same tine was cyanide fumigation of . . . well, j_ t 1ms narticularly for Jong staple cotton i'rom Egypt that they 1,rere bringing into the country. It's, I believe, the sari1e as the Sea Island cotton in this country but it was not available here at that time. Mrs. Whitaker: This was during the war years? Dr. Griffin: This was shortly c~fter the wal'." years, I think. It vms about that period. The cyanide fumes were . . . you might think of them as beinc veTy volati~e, but actually they were adsorbed and they would s ta~r for long pe::iods o:f' tic1e. I thin'.;: your ve gotten a bu11eti.n on hydrocyanic ac: d ftxr i.gation. Ttiey TJere furnie;a ting the ,:ot ton baJes under ,rac: 1.LL.. !1 lot of it tras being done uD at Boston. I went uD to Boston on that fucication lj business. The:/ had tanks that would hold perhaps 15 or 20 r bales of cotton, '8Ull the vacuur:1. on ther, and let the hydro­ cyanic acid gas in, and th~n force it into the bales by letting the vacuum dm,m and the e;as did get into t:1e r,liddle of the bales. We drove spikes into the bales and we analyzed the stuff that got into the bales and we also I night say that the gas would come out of the cotton for a long time afterwards. They Hould pull the vacuuc to try to get all tne hydrocyanic acld Ol,t of the cotton 2.nd then the bales 11ould be put in freieht cars and several ti.._es persons who had crawled in on ton of those bales of cotton got killed. They had also started using it for foodstuffs because they were fumigating buildings with it and it stuck in flour and various types of things for months. Mrs. Whitaker: Was Food and Drug involved in that as far as the administration of the Food and Drug Act or only fror: 1 the standpoint of . . . Dr Griffin: It was only f'ro:,1 the standpoint of research and the idea of whether or not h~.rdrocyanic acid was suitable for certain uses. Mrs .. Whi take1·: I read somewhere that cher:iical '::arfare service attempted to convert soc1e of the ,·.mr 6 ases ta do'.:·'.est::_c: uses after the 1•,ar. .. 16 Dr. Griffin: They undoubtedly did but that was not a war gas, as far as I know. Chloropicrin was a war gas. They attempted to use that but as far as I know never got anywhere. Mrs. Whitaker: Did you do any work with that? Dr. Griffin: I never did any work in the government with chloropicrin but carbonyl chloride was a similar thing that was used and I did work in organic chemistry at the University here with carbonyl chloride but I never worked with war gases. Mrs • Whitaker : What is your opinion on the ingredient statement permitted under the old Act of 1910? Dr. Griffin: Well, that was a very meaningless ingredient statement. It was not good. Mrs. Whitaker: In the hearings and the correspondence on forming that act, Dr. Wiley apparently changed his views and recommended giving the manufacturers the alternate. Do you know if that was the result of manufacturers' pressure or what brought this about? 17 Dr. Griffin: I can't say. It was before my time. Mrs. Whitaker: The question undoubtedly did come u:, again then as far 2-s amend~ents. In the 1J20's there were attemnts made to strengthen that aspect of the law. Dr. Griffin: There were certa~n amendments ~ade. I 1·ras not connected with administration at that time. Mrs. Whitaker: Did the question then come up again later in the 1)30'~ 1;hen you were with . Dr Griffin: I don't rer:1er.1ber r-rnything about it. It's ldnd of a touchy thing. It was alvrays felt that a L2n harl a right to a ce:ctain arno unt of sec rec,\ in his formulas ar:d to try to get i1L1 to give too much ~as difficult. l,1rs. Whi takeT: It would nrobr->,b}.v ha,ve contr_i. butec1 to ti-1c ormosi tion to thR i ._, • ~ - Act in the becinning? Dr. Griffin: Oh, yer,, yes. Mrs. Whita~er: During the 1)30's there were more atteLpts made to amend the act and one of t.he things that car,e up during the 1 :30' s 1-JaS the rtiatte!' of :•·odenticides. Were you doing any work with rodenticides in the Bureau? Dr. Griffin: No, we did no~ work with rodenticides until after the 1 47 Act was passed. Mrs. Whitaker: Do you have any recollection of those a~cnduents in the 1930 1 s, from what sources the:y r.1ight have coce? Dr. Griffin: No, I do not because they would not have filtered down to r;1e. I was doing chemical wori~ at that tir.1e. Virs. Whitaker: And the weed-t.illers also would have been from a later period, or did that question plague you already in the '30's? Dr. Griffin: If you will not~ce, the first drafts of the '47 Act did not include weed-}:::ill_ers and we felt at tl1e.t time that including rodenticides and the additional wor}::: 1·equired was about all the work we could 11andle. ~veed-killcTs needed some control but we felt that at that time we just couldn't take it on. ,,, At the hearings in this Act. before the Agricultural Com.L:ittee r one of the congressmen from California, I don't reme!Tlber h:i.s name now, as::ed ilny we hadn't put 1•Teed<::l..llers in there and I told him, I sun1Jose, something a1on 0 this line. He said he thought they ou~ht to be put in there and I told him that I thought they couJ.d be very easily nut in, that all it needed Has to insert the Hord "and weed-killers'' and to give a defi­ nition of weed- llers. I said that there wouldn't be any trouble about that. He asked what the definition was. Well I told him ti1e~,r' d have to put in a de.fini.. tion of weeds, And he asked what the defini..tion of weeds ',.'D.s and I told hi::-r1 just what's in the act there. He said that's the first time I've ever heard a governMent fellow co:. e out with such a 1 simole definition. Well, I said, it ~omes from your California law. Mrs. Whitaker: In California, the state law was . . . Dr. Griffin: It covered weed-;:;:illers at that tb1e. So that was the i•ray that weed-killers f□ t out into the bill. Mrs. WhitaKer-: I noticed on on.e of the drafts that ci l.:.':c1~ you r: ade tl1e co:~'. cnt 1 or someone r:w.rle the con!:,,e;-it that if '/O . jid not reword tJ-,e 1 connec tcd H.i. tr1 tr,c t? ·---------------------- Dr. Griffin: I do not. Mrs. Whi tat;.c ).': It was in connection ~-Ii th devices and the way the draft was ,·1ri tten it would include garden hoes as one of the devices. Dr. Griffin: I don It rerner::ber C 0 nything on that. Yirs . Whi take :r : You mentioned the hearings. Do yot:. recall . . . or weTe you involved :i.n o.n:y of the a-npropriRtions hearings throc.1 0 hout the '30's or r~·O's? Dr. Griffin; No, I was no0. I \·~as . . . well, you ;;a:1-d through the 1 L[O's. Of course I wo..s in the 1 40 1 s after the new act went into effect. I didn't usually attend conGressional hearings on ar1propriation::" b t I had the job of d!.·m-r~_ng up what ti1e needed 1• ':_;ersonnel ·was :::-~",G. des.crj bing the 2-1eeded 1,crsor.nel. ::rs. Whi tal<:.er: ·' D:·. 'J:r:'...f'fi :.1.; .. !' Dr. Griffin: I think we weren't treated any worse th~G other people. I think agri':::L'.lt'Jre 1:rc,s strong in those; cays. Of course agriculture no'.·r j s dead, ;,re tty nearl:.r, 2.,s far Dower is concerned. Even in the state of Kansas the vrbnn populatio~ has the rower. Mrs. Whi take :t: departr.oent? Dr. Grtffin: Oh, no. Thinc,s ,.."(; changed. T.lrs. Whitaker: Dr Gr-'tffjn: tables as fa:;:· bn.::::.': .:1-s l-~13 or 1-4. Dr·. GI'iffin: Pope. Poue Mrs. Whl taiter: Dr. Griffin: He was a che:,:1-rt. He ::;oent a lot of his time taking dO'im samples of frr:_:_ts and organic L1aterio.Jii- ·,r~"th sulphuric: 2ncl nitric acid and t~en deternining arsenic. Mrs. Whitaker: S::i th8 departricnt aware of the nroble~ . Dr. Griffj_n: It was aware or the nroblern and do5 n_c,; ':TOT~~ on it. I/~rs . Whitaker: How v.ras the BlTc,o.u of Biological SurveJ:=; involved in t l-"'c, .1..._,...,. work that you were doing? Dr. G-rif fin : During the ti:.:c that I 'd8..f: there it hctd no forrnal connection 1-ri th it. ':li tl1 it and =Lt tn.J,,[~ discussed with the . ~-n c:ases. to the arranc;uent you had wi tr1 the Fe6ei'al Trade Come is sion? :Or. Griffin: That's right. Mrs. Whitaker: . an inf or-. al exchange, throug~, tele~1hone, rather than . . . Dr. Griffin: Telephone, 01· 1:ersonal contact_, a r::erGon.al thing and noti1ing formal about :~t :::.c: far c1,s I irnow._ Virs . Whitaker : And do you rec~ll any of the dealings that you might have had with the Fcde:tal Trade Commission, for instance, on label claims? Dr. Griffin: No, as far as I knmr, the Federal 'l rade Com:1ission did not 1 c;o into label cla.:Lris. The Federal rl'Y-eJ1e Con~mission went into advertising and things that we couldn't tocch but as far aG I know they w've;' r;ot into labPl -; nc:. 11.rs. Whitaker: Did they object to vo1.1:r· gett:Lng i~to o,c''iertising or .vhat 1 l' ... le did advertising I'J.o:;/ j_n the cases trnt ".tere brought under the Act? Dr. Griffin: Advertising which acco:1:panied the product was considered labeling and the same thing that applied to labeling clai.Js applied to the 2,dvertising that accompanied the product in interstate coY.1r.;erce. Mrs. Whitaker: And then radio cor.1::-1ercials and things of that sort, you dj_d not deal with then? Dr. Griffin: We had nothinc to do with those. Mrs. Whitaker: Back to the question of rodenticides . . . when it was deter­ mined that they should be included in ti.1e 191~7 Act, what kind of poison was used? Dr. Grif'f'in: I would guess that about that time the th::..ng that was causine; t11e most trouble ~,.ras 1080. You' re nrob2.bly familiar wi tr. 11hat that stuff is. Mrs. Whitaker: Vaguely. Dr. Griffin: It is a very hlehly poisonous thing and it was tasteless. It was being used as a water solution of 1080 being put out for rats to dr:i.~l: a:1d it was very easy :for a child to drink the stuff. It Has <!_uickly fatal so ttw.t was probably the thing that we ilacl ti1e me.. st trc,uble with. Of course arseni cals had been used f'o::_~ a long time in baits, and phosphorus had been used fo::.~ :·:.ice but neither of those, as far as I know, caused considerable trouble. I think the anti-coagulants that hal/e been so successful in recent years came after that date. I wouldn't be sure just when tl1ey came. Mrs. Whitaker: Somewhere in ny reading I noticed that McDonnell raised the question of wl1ether or not a chemical that in one product would come under the insecticide act v1hen used in a rodenti­ cide would not come under the act. I did not find a form.al ruling on that. Do you recall what the department did in relation to that? Dr. Griffin: I don't quite get the question. Mrs. Whitaker: When a rat poison, for instance., had o,s one of its corimonents arsenic, you st~.11 could not bring charges against the product unless it was advertised as an insecticide also. Dr. Griffin: Well., that would. be true before the rodenticide act . . . during 26 J Dr. McDonnell's days that would be true. Of course if it was intended for uce as both an insecticide and a rodenticide we could worr:. on the rodenticide claii:1s but if it was only intended for use as a rodenticide we couldn't touch it. Hrs. Whitaker: That answers the ouestion that I had, yes. Dr. Griffin: ,..I If it came under our act, we required all claims to be accurate. If it did not cor.:e under our act, we couldn't touch it. Mrs. Whitaker: I have encountered in my readine; a number of stater:ients froL: Mr. W. S. Abbott, one in which he discussed the advantages and disadvanta~es of registration. This was during the 1920 1 s. Could you tell se anything about ~r. Abbott? Dr. Griff'in: 1-'.Ir. Abbott wac a very excellent entornoloc:ist. :re had held infantile par3.J.ysis '-'!hen he was a ch:l.1c1 and !1is legs had never de velo::icd. :-fe did all of his ::.~ield work in entor,oloc;:,' 011 crutches. Ancl :,is work was r,,os tJy fi cld worl~ and ::_ t ,·r2,s I feel that he ·.-ms one of the toD ,,en. Mrs. Whitaker: /\nparently Dr. Ha:/,,rood did also becawc;c he consulted h:L,;~ 27 on a number of occasions. Dr. Griffin: He was a good rnan:and well-balanced so that you could trust ·what he had to sa~r. Mrs . Whitaker : The fact that he raised the question of reGistration as a possible amendr:1.ent in the 1920' s would :Lndicate that his th:Lnking was sor:eu:1at ahead of his ti::1e. Dr. Griffin: ·t-rell., as I sa;/, he actually headed up the entor.iological work through a matte::.-- of, well, I don't k.nmJ just how many years but I guess it uas at least twenty years. His work was un­ questionably c;ood. But you would sec th:.s man with undeveloped twelve-year-old legs going along on a set of crutches . . . :-Irs. Whi ta}cer: It didn It hinder him at all in his field ':Tork.? Dr. Griffin: It didn't hinde:'.'.' h:i.r:'. in his field 1-mrl::. He was always e.. very indenendent sort of a guy. I remeuber at one tir:1e I thinl'" we were going dovm to Texas and we chan~ed trains in St. Louis. The station agent from Washington had .:v_Jparently seen I-1:r. Abbott, seen h1s condition, and they ~ad a wheel chair wajtfnG for hirn in St. Lo,.~:~s. I never saw anyone r1ore disgusted than Mr. Abbott '."!f!S. I think it vm.s nrobably on that saue 28 ., trip that we had been a little bit late in getting our reservations and they didn't have anything but upper berths and t'lr. Abbott swung himself up into an upper berth like nobody's business. Mrs. Whitaker: He must have been an outstanding man. Do you recall any other time in this early period when registration on the national level beca:r:1e the subject of discussion? I, Dr. Griffin: Not a subject of serious discussion as far as I know. It wasntt until we began to get the r1_t7 act in shape that it came up. Of course it had been done in states long before tilat. Mrs. Whitaker: What was your feeling about registration when you began discussing it seriously before the 1947 Act? 1 Dr. Griffin: Hell, I felt that it was probably a good thing and one of the things that was becoming necessary. An act which was good in 1910 was not sufficient in 1947 and one which was sufficient in 1947 is not sufficient now. 'rhings change and the law has to take account of it. Mrs. Whitaker: And it was a lonG time coming, this change, from 1910 to 29 .l 1947. Do you think that registration in that act, as far as the act perrai tted, worked? Dr. Griffin: In the 1 47 act? I certainly do. I think that if you had seen the amount of work that went into some 50,000 regis­ trations, I don't lmow how many there are now, but when I left there were some 50,000 . . . and each one of those labels was thoroughly gone over as carefully as could be done and the ar.1ount of correction that occurred was enormous. Mrs. Whitaker: What were the particular problems that you encountered in the registration? Dr. Griffin: Oh, there is always the question of over-rosy claims. If a thing will do one job, they thinl-;: it will do every­ thing so that we had to deflate claims. That was the principal thing. Of course the matter of composition, we quite frequently had hassles over what the statement of ingredients should be. Very often the r.1anufacturer didn't want to give that information and it was a job to make him see the light. Mrs • Whitaker : During the r.10nths in which you were v,rrj_ting the 1947 act, what was the ::1anufacturers' react:; on in an infor1nal 30 J. way to including registration? r Dr. Griffin: I think that a good many of them would rather not have seen the registration thing in there. Of course, the manufacturer doesn't like to see any requirement put in, but they came around in the latter part of the dis­ cussion, and the ingredient statement, or the registration was not seriously questioned as far as I ltnow. The question came • • • if you've got the copy of the hearing before Congress, the Congressional committee, you will note that the chairman toolc up in order each one of the criticisms that the manufacturers had made. As he took up the criti­ cism he asked me ·what the answer to that criticism was. The criticisms, as far as I recall, did not go particularly to registration. They went to other points. I never saw a hearing done in that way. The copy of the Act was brought in and the manufacturers had had a chance to criticize it and they had raised certain objections to it. The chain:ian went down the line each one of the objections--this is their objection, what is your answer to it? Mrs. Whitaker: I wanted to asl\. you just another question or two about your role with the Food and Drug Administration bef'ore 1938. Were you involved with the regulatory functions at that time? - 31 ... Dr. Griffin: I was involved in the regulatory functions while I was in the Food and Drug Administration. One of the things that I had to do, however, was to have charge of the equiprnent for the whole Food and Drug Administration in the South Building, Departnent of Agriculture. Of course, the building was built by the Department and our contacts were with the Department engineer and with the DepartE1ent ad.minis trator. 1.-Je had the job of allotting space and of designing the equipment. Of course we did not design it ourselves but each group was expected to tell us what they wanted and it was our job to r;et them in and get the thing done. Mrs. Whitaker: Did you contj_nue to worlr:: with insecticides during the time that insecticide control was part of Food and Drug Adninis­ tration1s functions? Dr. Griffin: Yes, insecticides and fungicides. I never worked parti­ cularly on any ot:1er product excer)t t:iose under the Acts. Hrs . Whitaker : Did you notice, during the time that insecticides were still under the Food and Drug Adminis tro.tjon, a growing awareness on the part of consu.'ners to the products -ehey 1·1ere using? In ti1.e very early period hardly anyone other 32 than you people and the manufacturers Here even aware that there was an insecticide act. When did you first notice that the public might have become more conscious of it? Dr. Griffin: I think that ti.1ey very definitely becar;1e more conscious, probably about the th::e that DDT and so:-:1e of the organic chemicals that 1,;ere 1c)sed in World ·Har I I were introduced. That was the big change. Mrs. Whitaker: Other than refo::_~:,1 and consumer groups v-:ho were actively in it, what vras the public reaction to the arsenical resi­ dues? Dr. Griffin: Back in the late teens there was a very heavy public reaction to the arsenicals because at that time the lead arsenate particularly was used as a heavy coating for apples to protect them from insects and very frequently you'd find, even after the fruit ·was picl::.ed, you I d find residues of load arsenate in the ste~s or in the blossou end. There was a lot of fear expressed. nrs. Whitaker: How did you feel, 1·!orking on this? 33 ,,,; Dr. Griffin: Well, actually, it never worried me too much. I didn't i•mnt it on the things that I ate but we used arsenicals around the laboratory and I did not have too r.mch trouble at first, let me say. We never did have any trouble, as far as I know, from lead arsenate. I am sure that one of our men was severely affected with Paris green. His name was Elliott--and I used to see him around with Paris green on his face and he 1,rould mix up Paris green paste with his hands and he alLost lost his eyesight. It had the effect of narrowing the field of vision and his eyesight got to be very bad. I think that it corrected later because they began to use a treatment to get the arsenic out of the system. We did have a bad case there, and I know that one of the other uen, C. M. Smith, was afraid that he had gotten some arsenic. ~e found that a considerable amount of arsenic had gotten into his hair from internal sources, grown into his hair. It has the effect, I believe, of coming out in the hair. Arsenic isn't a thing that you can use with impunity. Mrs . Whitaker : Did you advise those people working 1·1i tll you to take precautionary neasures? Dr. Griffin: I don I t know that I ,•ms in a position paTticularly to advise them. They were just as high rank as I was. They came to work at the same time I did. I guess none of us figured that arsenic could be quite as bad as it was. I did very little 1-mrk on arsenicals. Nrs. Whitaker: We talked earlier about disinfectants. Having scanned these notices of judgrn.ent, household cleansers, disinfec­ tants of all sorts played a very pror;1inent role in seizures? Dr. Griffin: As a matter of fact, by that time the lead arsenate, cal­ cium arsenate, Paris green had been pretty well gone over and the labelj_ng 11as pretty well standa::.~dized. There wasn 1 t too much trouble with them. t~st of them were manufactured by large manufacturers who had good control of their products--good chemical control--and we didn't run into too much trouble with theQ. TTe did run into trouble with the more or less fly-by-nights, the ones that had no laboratory facilities for testing them and just put them out to sell a product. Mrs. Whitaker: I suppose that having gotten the r:1ajor manufacturers accustomed to the act--Haywood had done some of that in his day--both funds and personnel were released to concentrate on disinfectants? 35 i. Dr. Griffin: We did try to get some samples from the big manufacturers so that we could check them. Mrs. Whita~r: Put them on their toes? Dr. Griffin: Keep them honest. Mrs. Whitaker: Did you have any dealings with the formation of the 1938 food and drugs act? Dr. Griffin: No, I had nothing to do with that. Mrs. Whitaker: Do you know anything about the nature of the conflict between the Public Health Service and the Food and Drug when Con­ gress took away the research funds for Food and Drug and gave them to Public Health Service? Dr. Griffin: No, I had nothing to do with that. Mrs. Whitaker: Do you think that the public in general assumed that if a product was registered this gave the approval of the 36 department to the product to an extent beyond what the department intended? Dr. Griffin: I think there was a certain amount of that. Of course, there was considerable discussion at various times about allowing them to have a registration number and put the registration nuuber on the package. He always objected on the basis that it would give an unacceptable view that the stuff had been guaranteed by the department. Mrs. Whitaker: Similar to the guarantee number that was issued under the old act? Dr. Griffin: That's right and that was cut out pretty quickly. Mrs . Whitaker : What were your feelings in the period before the 1947 Act about the seizure of goods instead of using the criminal information process? Dr. Griffin: That was a matter of the best way to enforce the act. ·when I :first vrent with the government I felt that when we brought crininal proceedings against a person the - 37 j general public 1 s reaction was that the government wouldn't ,. bring action against this fellow unless he'd done something ·wrong. It was very much easier to win a case in court on criminal charges at that time than it was later. Later they came to the view that, heck, this is oneof our home folks and what the heck is the goverm1ent doing coming down here and trying to prosecute hir.1. He's a good guy and he shouldn't be prosecuted. It was very much harder to do it. Now a seizure is a civil case and doesn't require the same amount of proof as a criminal case does. It's very much easier to handle a seizure case than it is a criminal case and very often a series of seizures would get the same results as a criminal case, so they went to seizures on that account. Mrs. Whitaker: Do you recall approximately what year this was? • Dr. Griffin: I imagine in the 1930 1 s. I recall a case that I went to down in Texas--i t was El Paso-- and it ,was on a product that was intended to be fed to the chickens to prevent chicken lice and t1i tes. There are products of that type now which work but at that time there 1•/'ere no products that worked and thj_s was purely a falrn. We went down to El Paso and came in to court on a Monday r.1orning and wanted to go to trial. The case came up then and the defendent 38 put in a motion--I've forgotten what the motion was at the l present time--and the judge said, we'll give you until Thursday to answer that motion. The U.S. attorney said that he'd like to go ahead with the case, these witnesses had been brought down from Washington and it had cost money to bring them dm-m. The judge said, that doesn't malrn any difference. The governr:ient will keep them here. He didn't think much of the government. The only thing we could do was to take it. The United States attorney said, I don't know anything about this thing. This man's got this motion and I have got to write a reply to it. He said, you take it and write the reply. So I took it and wrote a reply, and I took advantage of the fact that I wasn't supposed to lmow any law and I put in whatever I wanted in the way of argument. Well, apparently the argu­ r:ient that I put in persuaded the judge because when we went in to court the next Thursday or Friday he had turned right around and he gave us all the leeway we wanted and we got t' a c·onviction. We didn't ask for any heavy penalty. All that we asked was that the product be taken off the market. When the case came up for sentencing the judge asked before he sentenc-ed, 1.vill this stuff be taken off the market and the defendant said yes and the judge said, on that basis I' 11 fine you, I don't rer.1ember, ten dollars or something very minor, ·which ,,ras all we wanted. It accomplished our purpose which was to get it off the r:;arket. The people • r were poor people and they weren't people you wanted to have any vindictive thoughts of. .i Mrs. Whitaker: T Just to protect the consumer from what they were selling? Dr. Griffin: That's right. Mrs. Whitaker: Can you say at ·what point the Departr.1ent became more concerned with the consuraer' s well-being, other than his economic well-being? Dr. Griffin: Well, that of course came in the early 1 40 1 s during World War II. There ·were a lot of new products which came in. The organic cherJicals were much more prominent at that tine and there were a lot more products that the consumer didn't know what he was using. As far as an arsenical was concerned, the consumer always knew that arsenic was poison. If he got lead arsenic or calcium arsenic, he :::new that he had to take care of j_t. But the things that came in, the organic chemicals, were not familiar and it seemed to be necessary when they came in to give the consumer more pro­ tection. That's about the story as far as I know it. Mrs. Whitaker: The original intent of the old law ,·ms -~1rimarily to protect the consumer's econo □ ic interests? Dr. Griffin: To protect the consumer as far as effectiveness was con­ cerned, economic protection. But there 1ms nothing in the old law to protect his health or to protect him from per­ sonal injury. Mrs. Whitaker: Would the Department's interest in disinfecting materials-­ antiseptics, gerr.1icides--ha ve indicated a concern also 'With and a recognition of the responsibility toward public health? Dr. Griffin: A certain amount of that but not ,,1hether the product caused direct injury to the person. Of course, it caused indirect injury if it was ineffective and allowed him to get infected with some disease. The economic concern was still the major concern. Mrs. Whitaker: When your work beca:rae more adminis tra t::.. ve than chemical during the 1940 1 s and the discussion arose about the amended or adjusted bill, was the setting of standards a question of raajor significance? Dr. Griffin: I don't recall anything that was said at that time about setting of standards so I guess it wasntt significant. 41 Mrs. Whitaker: ... Would you tell ne something about your role after 1938 when Food and Drug went to the Federal Security Adminis­ tration and you stayed with the Depart □ ent of Agriculture? Dr. Griffin: By 1938 I had practically ceased to do any chemical worl~ and my work was virtually all administrative, largely handling correspondence with manufacturers and others that asked questions concerning the application of the law to their products and possible violations. There was practically no chemical work after that. Mrs. Whitaker: Was there any abatement in enforcement of the Act during the war period for any reason--production and scarcity of materials and things of that sort? Dr. Griffin: So far as I 'r..novr, there was no abatement of the enforcement of the Act. Of course we were interested in food then and insecticides are necessary for the production of food and so I think our work probably was increased if anything. Mrs. Whitaker: What would have been factors in that, i.ms there more adulteration of products, for instance? L Dr. Griffin: There wasn't r.10Te adulteration, no, bv.t along about that time the organic insecticides began to cor.1e in. That would be the productio:1 of DDT, the production of a number of things intended to prevent insects froM biting, mosquito repellants. There were quite a number of new materials that came in just about that period. Mrs. Whitaker: Were there new products that preceded DDT during the period between 1938 and approximately 19L~2 1:1hich might have been substitutes for the old arsenicals? Dr. Griffin: I would think that there were. I don't have any close enough recollection of what happened at what date so that I could say. I think that perhaps sorae of the published material that you have will show that. Mrs. Whitaker: Yes, I did see some reference to it and I wondered if that in any way influenced or affected the kind of enforce­ ment problem you □ ight have had. I noticed in the printed material the tremendous amount of agitation for an amendment to require coloring the white products that were mistaken for food frorri tir,1e to tirne. 43 Dr. Griffin: That applied particularly to sodium fluoride. Sodium fluoride did start to be colored at that time, colored blue. Mrs. Whitaker: And then when you began writing the new act, in about 1945, that was incorporated? Dr. Griffin: That was incorporated in the act. Mrs. Whitaker: In the matter of factory inspection, I noticed in the printed material that Dr. Haywood did not favor factory inspection; he felt it was not legal. But Food and Drug, when they took over the enforcement of the Insecticide Act, did use factory inspection. What was your feeling on that when you became an administrator? Dr. Griffin: Factory inspection is mostly a question of helping the inspector. The things that you accomplish by factory inspection are finding out what is being shipped, where it is being shipped, and get a general idea of the chemical I, composition to help the analyst. You can't by factory inspections make sure that the product is not adulterated or that it is what it claims to be. Of course, we had to prove interstate shipment in all cases. I notice that that is not required in the latest law. It helped prove interstate shipment. That's largely what it would do. Mrs. Whitaker: Was it the practice of the Insecticide Division after 1938 to utilize factory inspection to any e;reat extent or did you concentrate prinarily on the collection of samples? Dr. Griffin: 'dell, let me say that after 1938 the ins:r,,ectors were in the Food and Dru~ Ad□ inistration and I believe we ceased to have any inspectors directly connected with the insecti­ cide work. All of that would not come under our control at all. Mrs. Whitaker: Here you har:1pered by the limited number of inspectors that you had durin(; the war period when personnel were harder to secure? Dr. Griffin: We always wanted core inspectors. i;Irs. Whitaker: Well, you had very :few . . . I think the nost was seven. ,. 45 Dr. Griffin: .,. We had very fe-w. We had to keep a balance between inspection ·work and the nur,1ber of samples collected, and the number of samples that could be handled in the laboratories. I was never directly connected with the inspection work. Hy connections were with the laboratories and we had about as many samples as we could handle. Mrs. Whitaker: So an increase in the inspection force ,-muld not have helped you without further appropriations? Dr. Griffin: That's right. Mrs. Whitaker: You were involved then, after 1938, with the matter of appropriations. 1'lhat were your dealings with the Congress? Dr. Griffin: I did not have dealings with the Congress on appropriations after the 1947 Act except in the one case in 1947. The 1947 Act was passed just before Congress was to adjourn. We asked for an emergency appropriation of $50,000 to start its administration and were told to appear before a congressional co1m1ittee to support the request the next day. When we arrived the Navy was ask.in~ for a large amount, I think about *500,000,000. The hearing went on until noon or later. Then ca.me our turn. The Chairman said nDo you need this money?" I said nyes. 11 That finished the hearing. In deciding what money is appropriated estimates had to be made and we had to put in a request to the department. I usually had sor.1.ething to do with requesting new people, new equipment, or ·whatever. Mrs. Whitaker: What was the attitude of the department itself towards appropriations £'01~ insecticide enforcement work? Dr. Griffin: They never give you enough money but Ithink they're rea­ sonably fair. Mrs. Whitaker: On the matter of seizures, I notice in the printed material that Dr. Haywood attempted almost annually to get appro­ priations increased (and he did deal directly with the Congress) to expand the use of seizures. What are your feelings on seizures as compared to the criminal proceedings? Dr. Griffin: The difference between the two is that seizures are handled ,.J as civil cases and the requirements for proof are much less rigid than those in criminal cases. The criminal cases 47 require proof beyond reasonable doubt and they are much harder to carry. Also, a jury will consider a civil case which can only lead to a fine as much less serious and they are much more likely to give you a verdict than they are in a criminal case. If the seizures will accomplish the same purpose, and I think they did in most cases, the seizure is probably the preferable situation. Of course, there are sorn.e places where there are snall amounts and where a seizure can 1 t be made. Over the long run the seizures are a better procedure. Mrs. Whitaker: And you used seizures whenever you could when you reached the administrative level? Dr. Griffin: That's right. Mrs. Whitaker: You may already have answered this to ti1e extent that yoLl would be able to without the records here, but what deter- mined whether or not you decided to seize a product instead of bringing a criminal procedure? Dr. Griffin: You just considered the whole case and if you thought that the seizure would accomplish your purpose--getting it off 48 the market or getting corrections--the seizure was entirely adequate. The purpose in general of enforcement is to see that the people get the product that they should have. It isn't to punish anybody or anything of that sort; it is to accomplish results in the way of protection. Mrs. Whitaker: How did manufacturers feel about having their products seized? Did you generally get more reaction from the manufacturers through seizure? Dr. Griffin: I don't know that there was any difference. I think perhaps the manufacturer accepted the seizure more readily than he accepted a criminal case. After a seizure was made, we had the goods there and he thought they were gone, but what of it. But I think it accomplished the results we were after. Mrs. Whitaker: I have noticed in the printed material that appropriations were cut somewhat in the 1950 1 s for a year or so. Do you recall what the particular circumstances were? Dr. Griffin: I do not. 49 Mrs. Whitaker: In the preparation for presenting the new act--I think you wrote the first draft in about 1945, did you consider the question once again of bacteria? Dr. Griffin: Frankly, I don't remember just what we put in there. I think the bacteria were covered by the act. It has been a long time since I read the act. Mrs. Whitaker: They were covered and I wondered whether,you intended to expand the limits of the products covered? Dr. Griffin: No, there was no intention to expand. That first draft was written without discussions with other people, that was on my own. It was put up for somebody to kick at. :Mrs. Whitaker: It didn't get much kicking at. It came through pretty much the way you had written it the first time. Dr. Griffin: It came through a good deal that way . .. Mrs. Whitaker: There was a good deal of discussion, however. I think you Dr. G r i f f i n : Not a c l e a n s e r b u t a c l e a n s e r t h a t claimed d i s i n f e c t i n g power. Mrs . Whitaker : And you f e e l t h a t t h e y r i g h t f u l l y s h o u l d have been c o n t r o l l e d by t h e A c t ? Dr. G r i f f i n : There w a s n ' t a n y t h i n g else t o c o n t r o l them. I think t h a t a good d e a l o f t h e a d v e r t i s i n g , even a t t h e p r e s e n t time, goes hog w i l d on t h e d i s i n f e c t a n t c l a i m . Mrs . Whitaker : Who were t h e o t h e r people t h a t d i d a s s i s t you l a t e r w i t h t h e b i l l t h a t e v e n t u a l l y culminated i n t h e 1947 A c t ? Do you r e c a l l any o f t h e d i s c u s s i o n s or c o n f e r e n c e s t h a t you may have had d u r i n g t h o s e y e a r s ? I Dr. Griffin: I do remember, of c o u r s e , t h a t w e d i s c u s s e d them w i t h t h e s t a t e o f f i c i a l s , t h e s t a t e economic p o i s o n o f f i c i a l s . There were very c o n s i d e r a b l e d i s c u s s i o n s w i t h t h e man who r a n t h e manufacturing c h e m i s t s a s s o c i a t i o n - - I d o n ' t remember h i s name. There was Hamilton who was w i t h t h e Chemical S p e c i a l t i e s Association. We had c l o s e c o n t a c t w i t h him. He, by t h e way, i s s t i l l a l i v e and I get a c a r d f r o m him a t Christmas. 52 i I Mrs. Whitaker : I i What were t h e i r f e e l i n g s toward t h e b i l l ? Dr. G r i f f i n : Well, t h e y had a s t r i n g o f c r i t i c i s m s . We i r o n e d o u t e v e r y - t h i n g t h a t we c o u l d i r o n o u t between u s and t h e n , i f you w i l l remember t h e C o n g r e s s i o n a l h e a r i n g , t h e y came up w i t h a l i s t o f c r i t i c i s m s which t h e y had and which w e t r i e d t o answer and i n most c a s e s our answers were a c c e p t e d . Mrs . Whitaker : D i d i n d u s t r y a c c e p t t h e need f o r a change i n t h e l a w ? Dr. G r i f f i n : Yes, t h e y a c c e p t e d t h e need f o r i t . They knew t h a t i t was t h e coming t h i n g . They d i d n ' t f i g h t t h e a c t as a n a c t , t h e y o n l y f o u g h t c e r t a i n t h i n g s which t h e y d i d n ' t a g r e e with. They d i d n ' t l i k e t h e r e g i s t r a t i o n p r o v i s i o n . Mrs . Whitaker : Were t h e y f e a r f u l t h a t t h i s would unduly c u r t a i l t h e i r a c t i - v i t i es ? Dr. G r i f f i n : It meant t h a t t h e y would have t o submit t h e i r l a b e l i n g b e f o r e 4. t h e y p u t t h e p r o d u c t o n t h e market and t h a t , o f c o u r s e , d e l a y e d b and made a d d i t i o n a l d i f f i c u l t y . With the new l a w I d o n ' t s e e how a p r o d u c t i s e v e r going t o be p u t on t h e market. A. 53 A t t h a t t i m e we f i g u r e d t h a t t o p u t a p r o d u c t on t h e market f o r u s e anywhere n e a r foods would c o s t from a h a l f m i l l i o n t o a m i l l i o n d o l l a r s i n r e s e a r c h work. A t the present t i m e I would guess t h a t f i v e t o t e n m i l l i o n would be a low e s t i m a t e . Mrs . Whitaker: And s o i t w i l l i n c r e a s e t h e c o s t t o t h e consumer e v e n t u a l l y ? Dr. Griffin: Of c o u r s e i t w i l l . A f t e r a l l you c a n ' t s t a y i n b u s i n e s s i f t h e b u s i n e s s d o e s n ' t pay f o r i t s e l f . Mrs . Whitaker: On t h e matter of p e n a l t i e s , was t h e r e much f e e l i n g i n t h e department o r what was your f e e l i n g a b o u t i n c r e a s i n g t h e p e n a l t i e s f o r v i o l a t i o n o f t h e Act, compared t o t h e p e n a l t i e s imposed e a r l i e r ? c Dr. Griffin: I d o n ' t t h i n k t h e r e w a s much f e e l i n g a b o u t i t . The p e n a l t i e s are n o t t o o heavy. AS f a r as t h e f i n a n c i a l p e n a l t i e s a r e concerned--I d o n ' t r e c a l l j u s t what t h e y were--they are probably no rnore t h a n t h e d e c r e a s e i n t h e v a l u e of t h e d o l l a r . I went t o work a t $120 a month. T h a t ' s changed q u i t e markedly now. Mrs. Whitaker : I t ' s s u r p r i s i n g though t h a t t h e amount of t h e f i n e s imposed 54 1 by t h e c o u r t i n t h e very e a r l y y e a r s g e n e r a l l y r a n between i i one d o l l a r and f i f t y d o l l a r s a n d t h e n i n l a t e r y e a r s t h e p e n a l t y imposed d i d n o t a c t u a l l y i n c r e a s e a g r e a t d e a l o v e r that. Dr. Griffin: I n most c a s e s t h e p e n a l t i e s were t o make t h e m a n u f a c t u r e r s be more c a r e f u l of what he was doing. The n o t i c e of judgment was a c t u a l l y t h e g r e a t e s t punishment because t h o were used by t h e c o m p e t i t i o n . Mrs. Whitaker: And t h e p r a c t i c e of i s s u i n g n o t i c e s o f judgment began w i t h i n c e p t i o n o f t h e a c t and c o n t i n u e d through t h e time t h a t . . . Dr. Griffin: Through t h e t i m e t h a t I was t h e r e . Mrs. Whitaker : And you f e e l t h a t t h a t was a g r e a t e r d e t e r r e n t t o t h e manu- facturers than the penalties? Dr. G r i f f i n : I f e e l t h a t i t was. f4rs. Whitaker : Do you remember any p a r t i c u l a r comruents or complaints t h a t any m a n u f a c t u r e r might have made t o you d i r e c t l y ? i 55 Dr. G r i f f i n : No, I d o n ' t r e c a l l a n y t h i n g o f t h e s o r t . Mrs . Whi taker : What were t h e c i r c u r & t a n c e s t h a t l e d d i r e c t l y t o your s i t t i n g down, t a k i n g pen i n hand, and w r i t i n g t h a t f i r s t d r a f t ? Do you r e c a l l t h e c i r c u m s t a n c e s ? Dr. Griffin: The f i r s t Food and Drug Act came o u t i n 1906 and a b o u t f i v e y e a r s a f t e r t h a t , or f o u r y e a r s a f t e r t h a t , i n 1910 i t became desirable to write an insecticide act. A s I r e c a l l , the Food and D r u g Act was r e v i s e d a b o u t 1937 and a f t e r t h a t was rewised i t seemed t h a t a similar r e v i s i o n was d e s i r a b l e - - 1 w a s t a l k i n g t o Harry Reed a b o u t i t one day and he a g r e e d t h a t i t would p r o b a b l y be a good t h i n g for u s t o look i n t o r e v i s i o n of t h e i n s e c t i c i d e a c t . It was a t t h a t t i m e t h a t I sat down and w r o t e a rough d r a f t . From t h e n on i t g o t i n t h e works and went t h r o u g h t h e r e g u l a r p r o c e d u r e . hlrs. Whitaker : C e r t a i n l y you d i d n o t e n c o u n t e r t h e o p p o s i t i o n t h a t t h e Food and Drug r e v i s i o n d i d ? Dr. Griffin: A c t u a l l y , t h e f a c t t h a t t h e food and d r u g r e v i s i o n i n 1937 had been made gave u s a l i t t l e b i t o f h e l p because a l o t of t h e companies were a l s o i n t h e f o o d and drug f i e l d . After 56 t h e y had been worked o v e r by t h e Food and Drug A d m i n i s t r a t i o n , t h e y were more amenable. They had been s o f t e n e d up a l i t t l e . blrs . Whi taker : I t h i n k t h a t Haywood p r o b a b l y had t h e same advantage s o t h e r e would be a p a r a l l e l s i t u a t i o n . Dr. Griffin: Yes, I t h i n k s o . Mrs . Whitaker: I t h i n k w e ' v e a l r e a d y d i s c u s s e d t o some e x t e n t t h e p r o b l e n s t h a t r e g i s t r a t i o n d i d p r e s e n t for you a f t e r t h e a c t was a c t u a l l y passed. This r e q u i r e d , of c o u r s e , more a p p r o p r i - a t i o n s and more p e r s o n n e l ? Dr. G r i f f i n : That s right. L Mrs . Whitaker : Do you r e c a l l any o f t h e p a r t i c u l a r d e t a i l s o f how you s e t about c a r r y i n g out t h e a d m i n i s t r a t i o n of t h e a c t ? Dr. Griffin: Before i t was passed we had t o make some p l a n s as t o what s o r t of o r g a n i z a t i o n we would s e t up. Before t h e o r g a n i z a t i o n t h e r e w a s no r e g i s t r a t i o n u n i t i n o u r o f f i c e . W e had t h e chemical group and t h e b a c t e r i o l o g i c a l group i n Washington. I 57 By t h e time t h e a c t was s e t u p t h e chemical group, I b e l i e v e , had a l l been moved o u t t o B e l t s v i l l e and the b a c t e r i o l o g i c a l work had gone o u t t o B e l t s v i l l e . We had a v e r y small Washing- ton office. We had t o s e t up a Washington o f f i c e t o i n c l u d e people t o p a s s on t h e chemical l a b e l i n g . We brought t h e people who passed on l a b e l i n g i n t o Washington and w e had t o s e t up a r e g i s t r a t i o n u n i t t o handle t h e r e g i s t r a t i o n . It meant s e t t i n g up a completely new Washington o f f i c e . I went over and g o t a l i s t o f people t h a t I t h o u g h t would be needed f o r it. We g o t a l o n g f a i r l y w e l l b u t i t was a rough time t h e f i r s t year. Mrs . Whitaker : T h a t would have been t h e y e a r i n which you had t h e h e a v i e s t load. About how many y e a r s d i d i t t a k e you t o g e t t h o s e p r o d u c t s a l r e a d y on t h e market r e g i s t e r e d ? Dr. G r i f f i n : They were a l l p r e t t y w e l l r e g i s t e r e d , as I r e c a l l , i n t h e first year. Mrs. Whitaker : I n o t i c e d i n t h e c a s e s brought under t h e a c t i n i t i a l l y t h a t most o f them had n o t been r e g i s t e r e d . Dr . G r i f f i.n : That s p r o b a b l y t r u e . 5% Mrs. Whitaker : Do you r e c a l l any p a r t i c u l a r problems t h a t you d i d e n c o u n t e r w i t h t r y i n g t o b r i n g p r o d u c t s t o t r i a l which were r e g i s t e r e d by t h e department? Dr. Griffin: We d i d n o t handle t h a t p a r t o f i t . Our o f f i c e would make recommendations f o r p r o s e c u t i o n and t h e n i t would go t o t h e s o l i c i t o r ' s o f f i c e and t h e n from t h e r e on i t was up t o t h e solicitor's office. Mrs. Whitaker : What were t h e c i r c u m s t a n c e s t h a t would convince you t h a t a p r o d u c t s h o u l d be prosecuted--a product, t h a t is, t h a t was registered w i t h you? Dr. Griffin: If i t was s i g n i f i c a n t l y a d u l t e r a t e d , i f i.t was s i g n i f i c a n t l y d i f f e r e n t from t h e composition t h a t i t was supposed t o have, t h a t was a l m o s t s u r e l y a p r o s e c u t i o n c a s e . If it was a q u e s t i o n of very d e f i n i t e l y f r a u d u l e n t c l a i m s , t h a t would be a p r o s e c u t i o n c a s e . If i t w a s a c a s e where t h e c l a i m s were m a r g i n a l , t h a t t h e y were j u s t blown up t o some e x t e n t and c o u l d be c o r r e c t e d by correspondence, w e g o t them c o r - r e c t e d and d i d n o t recommend p r o s e c u t i o n . It was a matter of judgment and we used t h e b e s t we c o u l d . 59 Mrs. Whitaker : The method o f correspondence w a s used q u i t e f r e e l y ? Dr. G r i f f i n : I would s a y t h a t there were a t l e a s t f i f t e e n t o twenty c o r r e s - pondence c a s e s t o p r o s e c u t i o n c a s e s ... i t c o u l d be more than t h a t . . Mrs . Whitaker : And t h i s s o l v e d t h e problem i n some c a s e s more e f f i c i e n t l y t h a n p r o s e c u t i o n would have? Dr. Griffin: It s o l v e d them very e f f i c i e n t l y b u t p r o s e c u t i o n would p r o - b a b l y a l s o have s o l v e d them. It may have been t h a t t h e y s o l v e d some of them q u i c k e r because i n a c a s e o f p r o s e c u t i o n t h e s o l i c i t o r ' s o f f i c e d o e s n ' t want you t o go on d e a l i n g w i t h t h e company a b o u t t h e p r o d u c t . They want t o h a n d l e i t w i t h p r o s e c u t i o n , whereas i f we were h a n d l i n g i t by c o r - respondence w e c o u l d get i t done promptly and be f i n i s h e d w i t h it. Mrs . Whitaker : What was t h e d e p a r t m e n t ' s f e e l i n g on t h e m a t t e r of h a n d l i n g i t t h r o u g h correspondence? Was t h e r e a n y e x p r e s s i o n fror:: r t h e S e c r e t a r y , f o r i n s t a n c e , a b o u t how you handled t h e c a s e s ? 60 Dr. G r i f f i n : I n e v e r h e a r d any e x p r e s s i o n t h a t w e h a d n ' t handled them correctly. Mrs. Whitaker : Unless a complaint was lodged w i t h t h e S e c r e t a r y , you had f a i r l y f r e e rein, then? Dr. Griffin: Yes. There were very few c a s e s t h a t t h e S e c r e t a r y e n t e r e d . We had v e r y l i t t l e t r o u b l e from p o l i t i c a l s o u r c e s . We f r e - q u e n t l y had a Congressman come t o us a b o u t one o f h i s p e o p l e ' s p r o d u c t s b u t i n a l l e x c e p t one or two c a s e s t h e congressmen were gentlemen a n d we understood t h a t t h e Congressmen had t o do something for h i s p e o p l e and we would u s u a l l y go o v e r i t w i t h t h e Congressman and we would t e l l t h e Congressman what we thought t h e p e r s o n c o u l d r e a s o n a b l y c l a i m f o r h i s p r o d u c t and what we thought he c o u l d n ' t . The Congressman was u s u a l l y happy w i t h t h e r e s u l t s he g o t from u s and he would w r i t e something back t o t h e p e r s o n . I n one o r two c a s e s I had Congressmen t h a t were v e r y d i f f i c u l t t o d e a l with. Mrs. Whitaker : Do you remember t h e p a r t i c u l a r s o f these c a s e s ? Dr. G r i f f i n : I remember one Congressman, he was f r o n a s o u t h e r n s t a t e - - I w o u l d n ' t mention who he was--he had been i n Congress f o r a l o n g time a n d a p p a r e n t l y t h e r e w a s a v e r y i n f l u e n t i a l d r u g o u t f i t i n t h e d i s t r i c t t h a t he was r e p r e s e n t i n g and w e had recommended p r o s e c u t i o n on t h e c a s e . He k e p t u r g i n g me f o r . . . I guess c l o s i n g time a t t h a t time was f i v e o ' c l o c k . . . and I t h i n k t h a t I was s t i l l t a l k i n g t o him on t h e phone a t 5:30 or 5:45. He was a t t e m p t i n g t o get u s t o throw o u t t h e p r o s e c u t i o n . It was a j u s t i f i a b l e p r o - ' s e c u t i o n and I d i d n ' t throw i t o u t . I think t h a t t h e case was n o t p r o s e c u t e d b u t i t was n o t dropped i n my o f f i c e . Mrs. Whitaker: If i t was dropped, i t would have been a f t e r i t reached t h e solicitor's office? Dr. G r i f f i n : It would have been a f t e r i t reached t h e s o l i c i t o r ' s o f f i c e . And t h e n I had a n o t h e r one. H e t o o k D r . Reed and myself o u t t o e a t a t t h e c a p i t o l and he had a c a s e . . . well, he had a p r o d u c t which I d i d n ' t t h i n k much o f and he wanted u s t o drop o u r p r o s e c u t i o n . He mentioned t h a t he was on t h e a p p r o p r i a t i o n s c o r m i t t e e , t h e committee t h a t handled o u r a p p r o p r i a t i c n , and you know w h a t t h a t means. Mrs . Whitaker : T h a t would have been a p r e s s u r e d i f f i c u l t to r e s i s t . What d i d you do i n this c a s e ? 62 Dr. Griffin: A s f a r as 1 was concerned, we d i d n ' t dro:; t h e c a s e . I think we f i n a l l y went ahead w i t h t h a t c a s e and I t h i n k t h e c a s e was l o s t i n c o u r t . Mrs . Whitaker : You d o n ' t remenber t h e p a r t i c u l a r s ? Dr. Griffin: i 1 w o u l d n ' t go i n t o what t h e p r o d u c t was. Mrs. Whitaker : But t h i s i s i n d i c a t i v e t o m e of how you handled p r e s s u r e s . Some o f t h e l a t e r c r i t i c i s m a g a i n s t t h e department and some of t h e c r i t i c i s m , as you w e l l know, was a l o n g t h e l i n e s t h a t you d i d respond t o c r i t i c a l p r e s s u r e s , n a n u f a c t u r e r s ' p r e s s u r e s , b u t t h i s would i n d i c a t e t h a t you had n o t . Dr. Griffin: As f a r as I know, i n o u r o f f i c e w e n e v e r were i n t i m i d a t e d by p o l i t i c a l p r e s s u r e s . Now I won't say what happened f a r t h e r out the line. Ide d i d n ' t h a v e t h e f i n a l s a y s o . Mrs. Whltaker : And s o t h e p r e s s u r e might have been t r a n s f e r r e d from you t o ... Dr. Griffin: A c t u a l l y , t h e s e a r e t h e o n l y two c a s e s o v e r a l o n g l i n e t h a t 63 I can t h i n k of undue p o l i t i c a l p r e s s u r e b e i n g a p p l i e d a t our l e v e l . I n g e n e r a l I have a v e r y h i g h o p i n i o n o f con- gressmen. O f c o u r s e , a congressman's c h i e f j o b i s t o g e t re-elected. He n u s t s a t i s f y h i s c o n s t i t u e n t s . I always r e c o g n i z e d t h a t and I w e n t o u t of my way t o try t o h e l p him s a t i s f y h i s c o n s t i t u e n t s w i t h o u t compromising o u r j o b . Mrs. Whitaker : On t h e m a t t e r o f p r e s s u r e , what k i n d o f p r e s s u r e s d i d you g e t from t h e m a n u f a c t u r e r s t h e m s e l v e s ? Dr. G r i f f i n : Nothing b u t r e a s o n a b l e p r e s s u r e . I have s e e n a man cone down t o Washington who had p r e s s u r e s p u t on him. I a m very f i r m l y convinced i n one c a s e t h a t t h e nan was t o l d u n l e s s he c o u l d g e t what he was s e n t down f o r he d i d n ' t need t o corne back. I n t h a t c a s e , we d i d n ' t g i v e him any more t h a n he was j u s t i f l e d i n having. So I d o n ' t know what happened C when he went back. The p e o p l e who cane t o u s were v e r y f r e q u e n t l y under heavy p r e s s u r e . There w a s n ' t t o o much p r e s s u r e t h a t t h e y could p u t o n u s , as fa.r as I could s e e . Mrs. Whitaker : And the same k i n d of s i t u a t i o n would have e x i s t e d i n t h e p e r i o d b e f o r e 1347? Dr. G r i f f i n : The same s i t u a t i o n b o t h b e f o r e and a f t e r . 64 Mrs . Whitaker : I have h e a r d you l a t e r referred t o as a gentleman who was a l m o s t Mr. I n s e c t i c i d e ... c o u l d you t e l l me a b o u t how t h a t name cane t o be a p p l i e d t o you? Dr. G r i f f i n : I d o n ' t know t h a t t h a t name was p a r t i c u l a r l y a p p l i e d t o me o u t s i d e , b u t when I came t o r e t i r e one of t h e boys handed me a l i t t l e poem i n which he r e f e r r e d t o me as Dr. FIFRA, f o r t h e Federal I n s e c t i c i d e Fungicide & Rodenticide Act. Whether I was c a l l e d t h a t b e h i n d my back or n o t , I d o n ' t know. Mrs. Whitaker : Well, I t h i n k i t c e r t a i n l y was a compliixentary term or meant t o be. Dr. G r i f f i n : I b I'm sure i t was. Mrs. Whitaker : And you d i d , c e r k a i n l y , w i t h y o u r l o n g y e a r s o f e x p e r i e n c e w i t h b o t h t h e a n a l y t i c a l and l a t e r t h e a d m i n i s t r a t i v e work s e r v e as a s t a b i l i z i n g f a c t o r i n t h e d i v i s i o n . Dr. G r i f f i n : I was p r o b a b l y i n '55 .. . I was d e f i n i t e l y i n '55 t h e one who had t h e most e x p e r i e n c e on t h e law a n d l a w enforcement i n t h a t period. Mrs. Whitaker : You had a remarkably s t a b l e u n i t t h r o u g h o u t t h e y e a r s ? Dr. G r i f f i n : Yes, i t was a good u n i t . Mrs . Whitaker : D r . McDonnell had been c h i e f f o r ... Dr. Griffin: D r . McDonnell was c h i e f o f t h e l a b o r a t o r y when I went t h e r e i n 1913 and he s t a y e d c h i e f u n t i l 1945. M r s . Whitaker : So t h e r e was a c o n t i n u i t y ? Dr. Griffin: Very d e f i n i t e l y . Mrs . Whi t a k e r : Can you t e l l me wh u c n r m m b r a b o u t D r . McDonnell. H e ' s no l o n g e r l i v i n g now? Dr. Griffin: No, h e ' s no l o n g e r living. Dr.McDonnel1 loved b r i d g e . H e played d u p l i c a t e bridge very frequently. He was a S c o t s n a n 66 and he was one t h a t you c o u l d very d e f i n i t e l y depend on. He was a good b o s s . He was sometimes a l i t t l e b i t i n c l i n e d t o be t e r s e . I reriember one time d u r i n g t h e noon hour while t h e r e s t of u s were o u t of o u r l a b o r a t o r i e s he a p p a r e n t l y came i n t o r e a d t h e paper i n t h e r e and when we came back we found t h e c h a i r a t t h e desk . . . the office chair ... was b u s t e d t o p i e c e s . On t h e t a b l e was a n o t e , ''I t h i n k 1' you need a new c h a i r " a n d s i g n e d "C. C . PlcD. i Mrs. Whitaker : D i d he e x p l a i n ... Dr. Griffin: He d i d n ' t e x p l a i n a t a l l . One time when I . . . oh, maybe I ' d been t h e r e t h r e e or f o u r y e a r s . ..I g o t a bad l o t o f hydrogen p e r o x i d e a n d I opened one b o t t l e and t h e hydrogen p e r o x i d e was all gone. And I opened a n o t h e r and i t d i d n ' t work and I s e n t o v e r t o t h e s u p p l y room for a dozen more i b o t t l e s and I c o n t i n u e d t o open them and t h e y w e r e n ' t any good a n d f i n a l l y I g o t d i s g u s t e d a n d threw one of them o v e r i n a corner against the concrete w a l l . The n e x t morning I g o t a n o t e from D r . McDonnell--Please d o n ' t break any more g l a s s around because t h e j a n i t o r might g e t c u t c l e a n i n g i t up. T h a t was c h a r a c t e r i s t i c of him. H e d i d n ' t say r?uch b u t what he s a i d was p r e t t y c l e a r . Mrs. Whitaker : He came i n t o t h e p o s i t i o n of c h i e f of t h e I n s e c t i c i d e D i v i s i o n 67 a f t e r l o n g y e a r s o f working w i t h D r . Haywood f i r s t , and t h e n i n Food and Drug A d m i n i s t r a t i o n ? I n t h e e a r l y years o f D r . McDonnell's c a r e e r , he was doing a n a l y t i c a l work also? Dr. G r i f f i n : H e n e v e r d i d any a f t e r I came t h e r e b u t I t h i n k he p r o b a b l y d i d i n h i s f i r s t years. IIrs. V h i t a k e r : I n some o f t h e priizted r.iateria1, and this c a r r i e s u s back a g a i n t o t h e e a r l l e r p e r i o d a n d something we touched on b r i e f l y y e s t e r d a y , D r . Haywood's concern was w i t h t h e w e l f a r e of t h o s e peonle he was r e s p o n s i b l e f o r . I mentioned t o you, I t h i n k , s o x e t h i n g a b o u t h i s a t t e r i p t s t o s e c u r e pay raises f o r D r . McDonnell and t h e n I t h i n k you commented he d i d t h i s f o r you a l s o l a t e r ? Dr. Griffin: Yes, he d i d it Tor ne. I t h i n k I have a l r e a d y p u t on t h e t a p e h i s going o v e r t o t h e S e c r e t a r y . Firs. Whitaker : I ' m n o t s u r e you d i d . L e t ' s have t h a t a g a i n . I t h i n k we d i d n o t p u t t h a t on t h e t a p e . i Dr. Griffin: ? J e l l , t h e r e s t!ie s t o r y , o f c o u r s e , t h a t S e c r e t a r y \lilSori 68 was i n t h e h a b i t of c o n s i d e r i n g pay raises once a y e a r or perhaps t w i c e a y e a r a n d t h e l i s t was s u b m i t t e d t o him. According t o t h e s t o r y , he would s i g n them u n t i l h e g o t t i r e d a n d t h e n he would s a y , w e l l , 1'11 l e t t h e s e go u n t i l next year. A t one time D r . Haywood went o v e r a n d was q u i t e i n s i s t e n t t h a t h i s people be g i v e n pay raises. The S e c r e t a r y i n d i c a t e d t h a t t h e c o n f e r e n c e was o v e r a n d Haywood c o n t i n u e d t o argue and Wilson t u r n e d t o t h e nan he had there and s a i d , "Show t h e gentletien o u t . " T h a t ended t h a t . And t h e n a t a ! l a t e r time I had a n o f f e r t o go t o t h e General Chemical Company a t a c o n s i d e r a b l e raise o v e r what I had been g e t t i n g . I d i d n ' t a c c e p t a t t h e moment b u t I came back t o Washington 11 a f t e r a t r i p t o New York. D r . Haywood s a i d , "Have you a c c e p t e d . I said, no. He s a i d , "Wait a c o u p l e o f days and 1'11 see what I can do." I t h i n k w i t h i n two o r t h r e e days he had a raise t h r o u g h f o r me which, w h i l e i t w a s n ' t as h i g h as t h e General Chemical o f f e r , I d e c i d e d t o a c c e p t . r i b blrs . Whitaker : T h i s concern f o r your welfare seemed t o have i n s p i r e d a g r e a t d e a l of l o y a l t y f o r D r . Haywood from t h e people who worked f o r h5.x? Dr. Griffin: I think h i s p e o p l e were q u i t e l o y a l t o h i n . They f e l t he was one who was l o o k i n g o u t f o r t h e n . They l i k e d him. Xrs. Whitaker : i I n o t i c e t h a t D r . I4cDonnell s e r v e d as an a d v i s e r t o Haywood as h i s h e a l t h d e c l i n e d a few y e a r s b e f o r e h i s d e a t h . He was i n ill h e a l t h f o r a number o f y e a r s ? Dr. Griffin: Dr. Haywood was, y e s . H e c o n t i n u e d i n his o f f i c e b u t h e w a s n ' t t h e man h e ' d b e e n e a r l i e r . Mrs. Whitaker: H e c e r t a i n l y cones through from t h e p r i n t e d material as a v e r y dynamic person. Dr. Griffin: H e was. If he w a s anywhere i n t h e b u i l d i n g , you c o u l d hear him. Mrs. Whitaker : And he, o f c o u r s e , was t h e s u b j e c t o f abuse on a number of o c c a s i o n s f Tors d i s g r u n t l e d m a n u f a c t u r e r s '? Dr. Griffin: Yes. I don1-t know too much a b o u t t h a t because i t d i d n ' t come back t o u s a-tt h a t time. ?hi.Whitaker : One manufacturer who was q u i t e i n c e n s e d a t having h i s pro- d u c t surveyed o r exanined, I b e l i e v e c a r r j e d h i s feud o v e r t o your days? Dr. Griffin: Y o u ' r e r e f e r r i n g t o Mr. Harris? Mrs . Whitaker : Yes. Dr. G r i f f i n : I I Yes, he c a r r i e d i t on o v e r . He came i n t o t h e o f f i c e a t ! v a r i o u s times and w e f e l t t h a t he c o u l d n ' t be r e l i e d upon t o be u n b i a s e d i n h i s s t a t e m e n t s . A t one c o n f e r e n c e i n my o f f i c e I c a l l e d i n a s t e n o g r a p h e r t o t a k e down what was s a i d because I was a f r a i d of what niight b e said. I think the c u l m i n a t i o n of i t was when he asked for and was g i v e n a hearing i n t h e Secretary's o f f i c e . The h e a r i n g was headed by t h e s o l i c i t o r and w i t n e s s e s were heard. Harris's s t a t e - ments were t a k e n and t h e s t a t e m e n t s o f s e v e r a l w i t n e s s e s , i n c l u d i n g myself, were t a k e n . We were completely e x o n e r a t e d . I t h i n k t h a t nobody could have h e a r d Harris's s t a t e m e n t s a t t h e h e a r i n g w i t h o u t b e i n g convinced k h a t they w e r e n ' t entirely reliable. Mrs. Whitaker: Though you were e x o n e r a t e d from t h i s , 2ne a t t e n d a n t p u b l l c i t y was damaging t o your D i v i s i o n ? 71 Dr. Griffin: I d i d n ' t f e e l t h a t i t was damaging. I f e l t t h a t Harris's s t a t e m e n t s t a k e n on t h e i r own s t a n d i n g were n o t good. Mrs. Whitaker : He was n o t t y p i c a l of t h e k i n d o f p e r s o n s you d e a l t w i t h ? Dr. G r i f f i n : O h no, he was n o t t y p i c a l . He was v e r y u n u s u a l . Mrs. \$hitaker: Back t o t h e q u e s t i o n o f p r e s s u r e s . A f t e r a b o u t 1940 when you becane extrernely a c t i v e i n a d m i n i s t r a t i o n , we d i s c u s s e d c o n g r e s s i o n a l p r e s s u r e s and m a n u f a c t u r e r s ' p r e s s u r e s . Were you p r e s s u r e d i n any way by consumer groups? Dr. Griffin: Not t h a t I r e c a l l . Consumer groups i n t h a t day were n o t very important. Mrs. W h i t a k e r : And t h e e n v i r o n m e n t a l i s t s ? Dr. Griffin: I never h e a r d t h e word e n v i r o n m e n t a l i s t . It d i d b e g i n t o come on i n t h e v e r y last p e r i o d w i t h DDT p a r t i c u l a r l y but i t was n o t a n i:&iportant a s p e c t . 72 Mrs. Whitaker: I n r e t r o s p e c t t h e n , c o n s i d e r i n g a l l o f t h e emphasis t h a t has s i n c e t h a t time been p u t on t h e e n v i r o n m e n t a l a s p e c t s o f p e s t i c i d e s , t h i s was n o t one of t h e c o n s i d e r a t i o n s ? Dr. Griffin: It w a s n ' t a major c o n s i d e r a t i o n . O f c o u r s e , i n t h e Larger s e n s e w e always c o n s i d e r e d t h e environment. The Act r e q u i r e s t h a t t h e p r o d u c t must be safe when u s e d a c c o r d i n g t o t h e d i r e c t i o n s that a r e given. T h a t i s a n environmental s i t u a t i o n , i f t a k e n i n t h e larger s e n s e . If you t a k e i t i n t h e way i t has been u s e d r e c e n t l y , we d i d n ' t have t h a t . Mrs . Whitaker: Were you i n v o l v e d w i t h t h e I n t e r - d e p a r t m e n t a l Committee on Pes t i c i d e s ? Dr. Griffin: No, I was n o t i n v o l v e d i n t h a t . Mrs . Whitaker : W e were d i s c u s s i n g t h e m a t t e r of a r s e n i c a l s a n d t h e c r i t i - cism d i r e c t e d t o v a r d a r s e n i c a l s a n d you mentioned t h a t t h e c r i t i c i s m went back t o t h e e a r l y t w e n t i e t h c e n t u r y ? Dr. Griffin: It w e n t back t o . . I would s a y , l?,Jl4 o r 15. I was brought up on a farm i n New York s t a t e , t h e west bank of t h e Hudson 73 R i v e r a n d o u r p r i n c i p a l c a s h c r o p was a p p l e s . On a good y e a r w e ' d have a thousand barrels o f a p p l e s o r more. We had up t o t h e tii.ie I l e f t t h e farm i n 1303 o r 1904 never used any i n s e c t i c i d e on t h e a p p l e s . T h e a p p l e s were n o t p e r f e c t b u t s t l l l t h e y demanded a good p r i c e on t h e New York market. We shipped t o New York. The g e n e r a l u s e of arsenicals--the hefty use--started i n tile Northwest and had perhaps s t a r t e d b e f o r e t h a t t i n e . S i n c e t h e n i t has been i m p o s s i b l e t o r a i s e m a r k e t a b l e a p p l e s i n t h e Hudson River Valley w i t h o u t i n s e c t i c i d e s . The a r s e n i c a l s were used v e r y h e a v i l y on a p p l e s . The f r u i t was covered w i t h them and v e r y f r e q u e n t l y you would f i n d a white r e s i d u e i n t h e stem end o r blossom end of t h e f r u i t when t h e y came t o market, t h a t would have been from 151-5t o 1925. There was r e a l r e a s o n f o r worry a b o u t a r s e n i c a l r e s i d u e s on a p p l e s . When I f i r s t came t o t h e department o r s h o r t l y t h e r e a f t e r a l o t o f work was done on a r s e n i c a l r e s i d u e s i n o u r l a b o r a - tories. A chemist by t h e name o f Pope was a s s i g n e d t o t h a t work. H e was c o n t i n u a l l y t a k i n g down t h i n g s of t h a t s o r t - - fruit--with s u l p h u r i c and n i t r i c a c i d t o make a r s e n i c d e t e r - rainations. He had a p u b l i c a t i o n , I b e l i e v e , on t h e s u b j e c t . Mrs. Whitaker : There was very l i t t l e u n d e r t h e I n s e c t i c i d e Act t h a t c o u l d have been done a b o u t t h i s , You r e a l l y had no c o n t r o l o v e r t h e residue e x c e p t what Food and Drug had? 74 Dr. Griffin: No, t h e r e s i d u e w a s n ' t o u r problem. But s i n c e we were i n Food and Dru& we were doing t h e work. Mrs. Whitaker: The a n a l y t i c a l work? Dr. Griffin: That 's right. Nrs. Whitaker: Did t h i s present ny c o n f l i c t of _ - i t e r e s t - - a n ( I m r e l u c t a n t t o u s e t h a t s i n c e i t i s now s o overused--but was there a c o n f l i c t of i n t e r e s t i n your i n s e c t i c i d e s e c t i o n i n t r y i n g t o maintai-n a s t a n d a r d ? Dr. Griffin: I w o u l d n ' t s a y t h e r e was a c o n f l i c t o f i n t e r e s t . I would s a y t h e i n t e r e s t s were t h e same. We wanted t o have food t h a t was good t o u s e and s o d i d t h e y . There was sometimes d i f f i c u l t y between t h e e n t o m o l o g i s t s Trho were working o u t i n t h e f i e l d , t h e f i e l d man, and t h e food and drug. The f i e l d m a n ' s job was t o g e t marketable a p p l e s and he was working t o make r.!oney f o r t h e o r c h a r d i s t . He someticies made reconmendations which he knew o r c h a r d i s t s had been g e t t i n g away wl.th which we would n o t a g r e e w i t h . Mrs. Whitaker : Would he have been a s t a t e o f f i c i a l i n :.lost i n s t a n c e s ? Dr. Griffin: He could be s t a t e o r f e d e r a l . There have been c a s e s where t h e r e had been a c o n f l i c t o f i n t e r e s t between t h e two b u t I t h i n k t h a t i n a l l c a s e s where w e were a b l e t o show t h a t r e s i d u e s were t h e r e , we s t r a i g h t e n e d i t o u t . Mrs. Whitaker : Might t h e a t t e m p t t o f i n d a s u b s t i t u t e for a r s e n i c a l s i n t h e days b e f o r e DDT a n d t h e i n t r o d u c t i o n of o t h e r materials have been t h e r e s u l t o f t r y i n g t o f i n d some way t o r e l i e v e t h e o r c h a r d i s t o f h i s problems? Dr. Griffin: T h a t was one o f t h e t h i n g s t h a t would govern them i n t r y i n g t o get substitutes f o r arsenicals. I4rs . ifhitaker: Were you i n v o l v e d i n any way i n a t t e m p t l n g t o f i n d a p r o d u c t or was t h i s s t r i c t l y t h e m a n u f a c t u r e r s ' endeavor? Dr. Griffin: Tne o n l y one t h a t I worked on was o i l e n u l s i o n s . 1 did a c o n s i d e r a b l e ar?.ount of work on oil e m l s i o n s . They were used t o a l a r g e e x t e n t . 76 Xrs . Whitaker: A s a replacement f o r a r s e n i c a l s ? Dr. G r i f f i n : A s a replacement f o r a r s e n i c a l s i n some o f t h e s p s a y s c h e - dules. I n f a c t ny Ph.D. t h e s i s was connected w i t h t h a t work. Mrs . Whitaker : D i d you s e l e c t t h e t o p i c as a r e s u l t o f your work i n t h e department o r was i t t h e o t h e r way? Dr. G r i f f i n : A f t e r I had done t h e work, I d i d t h e ?h.D. thesis. Mrs. Whitaker : Do you r e c a l l , D r . G r i f f i n , when t h e word " p e s t i c i d e " f i r s t became p a r t of the language o f your d i v i s i o n ? Dr. G r i f f i n : I t h i n k t h a t i t was a f t e r t h e passage o f t h e '47Act. Per- s o n a l l y , I w a s n ' t v e r y f o n d o f t h e word p e s t i c i d e , I d o n ' t know why. I was r a t h e r d e s i r o u s o f c a l l i n g t h e a c t t h e I n s e c t i c i d e Act t h e same as t h e I n s e c t i c i d e Act o f 1910 b u t a f t e r d i s c u s s i o n we thought i t vould be more i n f o r c a t l v e i f we p u t I n s e c t i c i d e , Fungicide a n d 2 o d e n t i c i d e Act. The weed k i l l e r was p u t i n a f t e r t h e o r i g i n a l d r a f t s o f t h e a c t had been made and we n e v e r d i d g e t t h e rreed k i l l e r i n t o i t s name. Probably t h a t would have b e e n a l i t t l e b i t too cumbersome. P e s t i c i d e , I g u e s s , was a good t e r n and I have used i t i n r e c e n t y e a r s when I have t a l k e d a b o u t them b u t a t t h a t t i m e I w a s n ' t v e r y fond o f i t . Flrs . Whi ta..;e r : There was soxe concern t h a t t h e m a n u f a c t u r e r s might n o t l i k e t h e terc! p e s t i c i d e because of t h e c o n n o t a t i o n o f p e s t s ? Dr. Griffin: I t h i n k t h a t ' s probably t r u e . Xrs. Whitaker : D i d you h e a r ar,y cocunents y o u r s e l f ? Dr. Griffin: I d o n ' t r e c a l l any comments from i n d u s t r y on t h a t b u t I can see why i t would probably be t r u e . rI Krs . Whitaker : L I want t o go back a l s o j u s t a n o t h e r moiient t o t h e t r a n s j t i o n of a d m i n i s t r a t o r s a n d t h e f a c t t h a t t h e r e was a g r e a t d e a l qf s t a b i l i t y i n the I n s e c t i c i d e D i v i s i o n . D r . bIcDonnel1 had been w i t h t h e s e r v i c e even l o n g e r t h a n you had and 1'1 s u r e t h e n t h a i you clanaged very well t o a c q u a i n t D r . Reed xhen he came i n r r i t h t h e work t h a t had been done. Could you t e l l me s o : > e t h l n g a b o u t D r . Reed and t h a t p e r i o d o f transition? Dr. G r i f f i n : D r . Reed came fror.1, I b e l i e v e , t h e meat i n s p e c t i o n s e r v i c e . He w a s a v e t e r i n a r l a n and was n o t familiar w i t h p e s t i c i d e regulation. He a c c e p t e d a d v i c e v e r y r e a d i l y . I n f a c t , he a s k e d f o r it. Xy r e l a t i o n s w i t h him were always very p l e a s a n t and I t h i n k t h a t w e worked t o g e t h e r v e r y w e l l . I think that he d i d a b e t t e r j a b o f going o u t t o t i a n u f a c t u r e r s ' a s s o c i a t i G n s and g e t t i n g a r o u n d w i t h t h o s e people t h a n I would. On t h e o t h e r hand, he gave me a very f r e e hand and f u l l c o o p e r a t i o n i n c a r r y i n g o u t t h e a p p l i c a t i o n of t h e Act and c a r r y i n g o u t t h e t e c h n i c a l work t h a t was n e c e s s a r y ir, i t s application. Mrs. Whitaker : He l e f t t h e f o r m a t i o n of p o l i c y f a i r l y w e l l i n your hands? Dr. Griffin: Fairly well. He n e v e r changed any p o l i c y t h a t I started t h a t I can remember. We had no d i f f i c u l t y i n t h a t l i n e at all. I t h i n k he gave me a p r e t t y f r e e hand. Mrs. Whitaker : And h i s r e l a t i o n s h i p w i t h Food and D r u g and t h e o t h e r bureaus t h a t you had c o n t a c t w i t h ? Dr. G r i f f i n : I d o n ' t know t h a t he had v e r y much t o do w i t h Food and D r u g . I t h i n k t h a t a l l t h e r e l a t i o n s w i t h Food and D r u g were c a r r i e d 79 o u t by p e o p l e under him a n d I doubt i f he had any very d i r e c t r e l a t i o n s h i p wl f;:i tnem. Mrs . Whitaker : Other t h a n t h e requj-rements l a t e r on t h e r e g i s t r a t i o n and h e s t a b l i s h m e n t o f t h e t o l e r a n c e o r no t o l e r a n c e , what were your r e l a t i o n s w i t h Food and Drug d u r i n g t h i s p e r i o d ? Dr. Griffin: They were q u i t e i n f o r m a l . I t h i n k t h a t the people i n our o r g a n i z a t i o n would i n f o r m a l l y a s k t h e Food and Drug i f t h e y had any o b j e c t i o n s t o t h i s use o r t h a t u s e o f a p r o d u c t and where u s e seemed t o c o n f l i c t w i t h t h e i r views, w e w o u l d n ' t permit it. Sor.;e p r o d u c t s would be s u b j e c t t o b o t h t h e Food and Drug Act and t h e I n s e c t i c i d e Act a n d i n t h o s e c a s e s rue d i d n ' t a c c e p t them u n t i l i t seemed a c c e p t a b l e t o Food and Drug. Again, o u r r e l a t i o n s were good. Sometimes as y o u ' v e n o t i c e d from t h e v e r s e a b o u t Wales w e t h o u g h t t h a t t h e y were a l i t t l e bit s t i c k l e r s b u t n o t bad. Mrs. 'dhitaker : Do you have r e f e r e n c e t h e r e t o t h e t o l e r a n c e s perhaps or the ... Dr. Griffin: Well, t h e t o l e r a n c e s , also, w e d i s c u s s e d w i t h t h e n . I ?lad r e f e r e n c e t o b o t h claims and t o l e r a n c e s . We t r i e d n o t t o a c c e p t any c i a i x s or t o l e r a n c e s t n a t would be e m b a r r a s s i n g 80 t o Food and Drug. Mrs. Whitaker : There were sone p e r s o n s i n Food a n d Drug and a l s o i n t h e American Medical A s s o c i a t i o n who f e l t t h a t t h e a e r o s o l s p r a y s were abused. >?hat were t h e views o f t h e I n s e c t i c i d e D i v i s i o n on t h a t ? Dr. Griffin: I ' m n o t f a m i l i a r w i t h j u s t what a e r o s o l s t h e y were c r i t i c i z i n g o r j u s t what i t was. We t r i e d t o keep c l a i m s f o r a e r o s o l s w i t h i n r e a s o n a b l e bounds. Whether t h e r e were any o f t h e aerosols . .. I presume t h a t you have i n mind t h e p o s s i - b i l i t y o f danger from b r e a t h i n g a e r o s o l materials. In a good many c a s e s , as I r e c a l l , w e r e q u i r e d them t o be u s e d and t h e n t h e room evacuated u n t i l t h e a e r o s o l had had a chance t o d i s p e r s e . I d o n ' t r e c a l l t h a t we had any c o n f l i c t s t h a t were n o t r e s o l v e d by d i s c u s s i o n . I4rs. Whitaker : I would i n v i t e you now t o a d d any r e c o l l e c t i o n s . . . anythi-ng t h a t you might rerieinber o f your p e r s o n a l r e l a t i o n s h i p s w i t h any o f t h e s e people t h a t we've discussed--3TcDonnell and Xaywood . Dr . G r i f f i.n : $ J e l l , I t h i n k t h a t I ' v e p r e t t y w e l l , :?h.Lle we were d i s c u s s i n g 81 them, g i v e n you x o s t o f my r e m i n i s c e n s e s of them. I would s a y t h a t throughout t h e time t h a t I was t h e r e my r e l a t i o n s w i t h my b o s s e s , i n c l u d i n g t h e t h r e e t h a t you have mentioned, were very s a t i s f a c t o r y . I w o u l d n ' t say t h a t w e d i d n ' t d i s - a g r e e a t times b u t I c a n ' t conceive of having a b e t t e r bunch. Ilrs. Whitaker: T h a t would b e Eaywood, McDonnell, and Reed? Dr. Griffin: Haywood, McDonnell and Reed. They were v e r y s a t i s f a c t o r y p e o p l e t o work w i t h . I n o t h e r words, t h e y u s u a l l y l e t ne have my own way and do as I d a r n e d n l e a s e d . Mrs . Whitaker : i;Jell, I t h i n k t h a t would be a good n o t e t o c l o s e on f o r t h i s s e s s i o n and if we t h i n k of a n y t h i n g t o be added w e mizht do t h a t l a t e r on. Thank you. Dr. G r i f f i n : I w i l l s a y t h i s , t h a t i n t h e time t h a t I was t h e r e I never had any of t h e n cone back t o me a f t e r a khing was done a n d c r i t i c i z e me f o r having done i t . No second g u e s s i n g . Firs. Whitaker : You r e t i r e d i n 1(?4. D r . Griffin: 1955. 82 Flrs. Whitaker : So you were still i n c h a r g e of much o f t h e a d m i n i s t r a t i v e work i n t h e i n i t i a l p e r i o d of t h e r e l a t i o n s h i p between Food and D r u g and t h e I n s e c t i c i d e D i v i s i o n as f a r as t h e Miller Amendment t o Food a n d Drug? Dr. Griffin: I d o n ' t t h i n k t h a t came i n t o e f f e c t u n t i l a f t e r I l e f t . t Mrs. Whitaker: The c r i t i c i s n t h a t t h e Department o f A g r i c u l t u r e and s p e c i - f i c a l l y t h e i n s e c t i c i d e people were s u b j e c t e d t o came a t a p e r i o d l a t e r t h a n your s e r v i c e ? Dr. Griffin: I c a n ' t remember any s e r i o u s c r i t i c i s t i . We w e r e n ' t p e r f e c t b u t we t h i n k t h a t w e d i d n ' t g e t any n o r e c r i t i c i s m t h a n n e probably deserved. f b Mrs. Whitaker : Do you have a r e c o l l e c t i o n o f t h e A l b e r t Deutsch a r t i c l e s i n 1949 and t h e joint statement t h a t the Department o f P.gri- c u l t u r e and Food and Drug made concernLng DDT on d a i r y p r o d u c t s ? Dr. Griffin: I d o n ' t have any r e c o l l e c t i o n o f t h a t . 83 Mrs. Whitaker: I d i d have one n o r e q u e s t i o n t h a t I wanted t o a s k and t h a t concerns r e g i s t r a t i o n under p r o t e s t . I notice that this was n o t i n y o u r o r i g i n a l d r a f t and I c o u l d n o t f i n d where i t was i n t r o d u c e d o r under what c i r c u m t a n c e s . Do you r e c a l l anything on t h a t ? Dr. Griffin: The p r o v i s i o n f o r r e g i s t r a t i o n u n d e r p r o t e s t was i n s e r t e d a f t e r t n e r e was o b j e c t i o n by m a n u f a c t u r e r s t h a t t h e l a w as o r i g i n a l l y proposed would g i v e a government o f f i c i a l a u t h o r i t y t o r e f u s e r e g i s t r a t i o n w i t h o u t a h e a r i n g or w i t h o u t any o t h e r l e g a l r e s t r i c t i o n s . The m a n u f a c t u r e r s f e l t t h a t s u c h a u t h o r i t y would be too much, t h a t t h e y s h o u l d have some method of keeping a p r o d u c t on ti:e x a r k e t . A s a result, t h e p r o v i s i o n under p r o t e s t was i n s e r t e d and as a matter o f a c t u a l p r a c t i c e , i t was n o t used t o any g r e a t e x t e n t . 1 do n o t r e c a l l a s i n g l e p r o d u c t which was r e g i s t e r e d under p r o t e s t d u r i n g t h e time t h a t I was t h e r e . There may have been o n e o r two b u t t h a t would be t h e limit. I think that t h e r e g i s t r a t i o n under p r o t e s t was n o t a t h i n g t o be w o r r i e d a b o u t because LI" a p r o d u c t was r e g i s t e r e d under p r o t e s t and a u s e r b r o c g h t s u i t f o r i n j u r y o r any s o r t c e r t a i n l y t h e m a n u f a c t u r e r would be behind t h e e i g h t b a l l i n d e f e n d i n g a suit. . 1:lrs. Whitaker : There was a p r o v i s i o n a l s o , I b e l i e v e , for even h e a v i e r p e n a l t i e s if t h e department brought sci-t? Dr. G r i f f i n : I b e l i e v e t h e r e was b u t t h a t was n e v e r used d u r i n g t h e t i n e t h a t I was t h e r e . I Nrs. Whitaker : Do you r e c a l l , was t h i s M r . H i t c h e n e r ' s r e q u e s t ? Dr. Griffin: Mr. H i t c h e n e r , t h a t was t h e e x e c u t i v e s e c r e t a r y of t h e manu- f a c t u r e r s ' a s s o c i a t i o n , I can g l v e :jOU the name i f you want it. He was qcLte p r o n i n e n t d u r i n g t h e time t h a t I was < h e r e . Mrs . Whitaker : Do you t h i n k t n a t t h e p r o p o s a l carfie fror.1 h i s o r g a n i z a t i o n ? Dr. Griffin: I t h i n k it probably d i d b u t I . . . it !31ght have coli;e f r o c Plr. H a n i l t o n ' s o r g a n i z a t i o n o r i t n j & t iiave cone from 115s. Both of t h e o r g a n i z a t i o n s were a c t l v e . blrs . Whitaker : I n d i s c u s s i n g t h i s , was t h e r e no s e r i o u s o b j e c t i o n r a i s e a t o i t by governnent? Dr. Griffin: No. A s I say, i t ;vas a c t u a l l y o f vex-y l i t t l e i x p o r t a n c e . Mrs. Whitaker : k!e have n o t t a l k e d uuch a b o u t DDT because i t has been t h e s u b j e c t of s o much d i s c u s s i o n e l s e w h e r e b u t I wonder i f you f e e l t h a t DDT was t h e c a t a l y s t , p e r h a p s , t h a t brought a b o u t t h e 19br( A c t ? Dr. Griffin: It was one o f s e v e r a l p r o d u c t s which c a m i n a b o u t that tirile. DDT was t h e most j.::?portant of them b u t t h e r e were s e v e r a l others also. I.:rs. Whitaker: E a r l y i n 1950, a f t e r t h e s e r i e s of a r t i c l e s by A l b e r t Deutscii, I n o t i c e d i n t h e S e c r e t a r y ' s correspondence t h a t a good nany consumers began w r i t i n g t o t h e Departnent e x p r e s s i n g concern and alarm. Was t h e r e any of t h i s alarrn f e l t w i t h i n t h e Department that you can r e c a l l ? Food and Drug, I t h i n k , was concerned b u t I wonder how t h e Departr>ent o f A g r i c u l t u r e f e l t a b o u t DDT a t t h a t t i m e ? Dr. Griffin: Well, t h e Departi.>ent o f A g r i c u l t u r e v a s undoubtedly concerned with it. However, a l a r g e p a r t o f t h e e v i d e n c e on which t h e concern was based came a f t e r I l e f ' t t h e Department. It was a t h i n g t h e t was b u i l d i n g up a t t h e x i p e t h a t I l e f t . 86 Xrs. W h i t a k e r : a:id l;.55 t h e r e w a s n ' t as much concern f e l t So, between 1 ~ 3 0 i n your d i v l s i o n . For i n s t a n c e , t h e r e was no r e l u c t a n c e t o c o n t i n u e r e g i s t e r i n g p r o d u c t s t h a t c o n t a i n e d DDT? Dr. Griffin: I would s u s p e c t , w i t h o u t r e c a l l i n g d e f i n i t e l y , t h a t we were probably more c a r e f u l a b o u t some o f t h e u s e s where i t n i g h t g e t i n t o foods. I d o n ' t t h i n k t h a t w e were concerned a t t h a t t i n e w i t h t h e widespread o c c u r r e n c e of DDT which has been r e p o r t e d s i n c e t h e n . Mrs. Whitaker : Have you t h o u g h t of a n y t h i n g s i n c e o u r l a s t c o n v e r s a t i o n t h a t you might wish t o add t o t h i s ? Dr. Griffin: No. a. . 87 INDEX Abbott, W . S . , 26-27 A d v e r t i s i n g , 24 A e r o s o l s p r a y s , 80 R l s b e r g , Carl L., 1 American Medical A s s o c i a t i o n , 80 Antiseptics, 40 A p p r o p r i a t i o n s , 2 0 , 45, 46, 56, 61 A r s e n i c , 11, 33 Associations , aanufacturers , 8, 51 B a c t e r i a , 45 Calcium a r s e n a t e , 1 0 C a l i f o r n i a I n s e c t i c i d e Act, 19 Carbonyl c h l o r i d e , 11 Chemists, 6 Chemical S p e c i a l t i e s A s s o c i a t i o n , 51 C h l o r o p i c r i n , 16 Coad, B. R . , 10 Coloring amendment, 42-43 Consumer groups, 3 2 , 71, 85 Cyanide f u m i g a t i o n , 1 4 DDT, 3 2 , 75, 83 D i s i n f e c t a n t s , 2, (1, 34, 40, 50, 51 D o r s e t , Marion, 3 Emery, James, 7 Entomologists, 7 L Environment, 72 Environmentalists, 71 F a c t o r y I n s p e c t i o n , 43 F e d e r a l I n s e c t i c i d e , Fungicide & Ro- d e n t i c i d e Act, 28, 46-47, 53, 55 F e d e r a l Trade Coimission, 2 3 Food, Drug a n d I n s e c t l c i d e Adminis- t r a t i o n , 10, 13 Food and Drug Act, 1 2 , 15, 35 Food, Drug & Cosmetic Act, 55 Food and Drug A d m i n i s t r a t i o n , 73 Germicides , LCO G r i f f i n , E. L . , e a r l y c a r e e r , 1, 2 , 9, 1.3, 53, 56-56, 73, 76; w i t h FDA, 30; a d m i n i s t r a t i v e Work, 3 0 , 41, 43, 45, - ~. 47, 61, 6'2; w r i t i n g 1947 a c t , 4,),32, as Dr. FIFKA, 64 Gypsy n o t h , 13 Harris, P. F . , 70-71 Haywood, J. K . , 1, 4, 7, 9, 10, 13, 56, 67-68, 69, 81 Health h a z a r d s , from i n s e c t i c i d e s , 33, 40 H i t c h e n e r , Lea, 84 Houston, David F. , 8 Hydrocyanic a c i d g a s , 14 Inspectors, 4, $4 I n g r e d i e n t State::;ent, 16 I n s e c t i c i d e , a g r i c u l t u r a l , 3 ; rranufac- t u r e o f , 13 I n s e c t i c i d e Act o f 1910, 2 8 ; amendi:,ent toy 17 I n s e c t i c i d e & F u n g i c i d e Board, 12 I n s e c t i c i d e & D i s i n f e c t a n t Manufac- turers ' A s s o c i a t i o n , 84 Labels, 23, 52 Lead A r s e n a t e , 33, 40 L i c e , 37 Manufacturers, r e l a t i o n s w i t h , 7, 30, 58-59, 62-63; a t t i t u d e toward, 3 8 , 51 McDonnell, C. C . , 3, 6, 7, 65-67, 77, 81 Oil emulsions, 73 Olive Building, 7 Organic i n s e c t i c i d e s , 32, 39, 42 Paris g r e e n , 33 P e s t i c i d e , u s e o f word, 76-77 Phenol c o e f f i c i e n t , 9, 11 P o l i t i c a l p r e s s u r e s , 8, 60, 62 Quaintance, A . L . , b Reed, Harry, 53 Reed, Webb, 61, 7'(-78, 81 R e g i s t r a t i o n , 2 - ( - ? ~ > ,36, 56-37; under p r o t e s t , 83