An Interview with A. D. Cromartie
     This document is a transcript of an interview with
A. D. Cromartie conducted by Adelynne Hiller Whitaker
concerning enforcement of the Insecticide Act of 1910
and the Federal Insecticide, Fungicide, and Rodenticide
Act of 1947.    The interview was held in Mr. Cromartie's
home at 1604 South Lakeshore Drive in Sarasot~Florida,
March 26, 1973.
     Mr. Cromartie joined the Department of Agriculture
as an inspector assigned to the Food and Drug Adminis­
tration in 1931.    From 1945 until his retirement in 1966
Mr. Cromartie was in an administrative position in en­
forcement and inspection with the Insecticide Division
of the Department of Agriculture.
     Mrs. Whitaker is a doctoral candidate at Emory
University, writing a dissertation on "Pesticides and
Regulation. "
                                                            1

Mrs • Whitaker:
Mr. Cromartie, would you begin by telling me something
about your career, when you went with the Department?


Mr. Cromartie:
I first went with the Food and Drug Administration in
1931 as an inspector in    Los   Angeles, California.   After
about three years there I transferred to San Francisco,
California, where I spent about three and a half years.
Then, from San Francisco, I was transferred to Boston,
Massachusetts, where I stayed until 1941, January the
1st, at which time I transferred back to the Insecticide
Division.in Agriculture.     In 1941 I was transferred to
Atlanta and covered the six southeastern states until
April 1945 at which time I was transferred to Washington.
I was transferred to Washington as a chief inspector
at which time we had five, if I remember correctly.
There was one on the West coast that covered the territory
from the Canadian border to the Mexican border; one in
Chicago that covered from the Canadian border down to the
Southern states; one in Baltimore that covered part of
the Southern states; one in New York that covered the
Northeastern states; and the Atlanta station covered
the seven Southeastern states which was cut back one
state in 1942.    From 1945 to 1966 I was employed in
washington as an administrative officer which covered
the enforcement and inspection work.       At the time I
retired I was chief of the inspection and registration
section.
                                                           2


Mrs. Whitaker:
Your time in government included the period when it was
under Food and Drug and you were under the supervision
of Mr. Campbell?   When you went back to Agriculture,
who was the first chief with Agriculture?


Mr. Cromartie:
Dr. Reed took over.   Dr. Reed is the one that took me
back to Washington.   Dr. McDonnell was chief of the
Division when I transferred over.    The fact is, he had
been chief of the Division from the time Dr. Haywood
died until he retired at the age of 70.     At that time
we were under the Livestock Branch in PMA, AMS--they
changed names during the war--and at that time in Wash­
ington there was Dr. Reed as chief of the Division,
Dr. Griffin assistant chief.    Each had a secretary.
I was administrative officer.    I had a secretary.     There
was a clerk typist and two file clerks.     That was the
force that operated at that time, along with the five
inspectors.


Mrs. Whitaker:
Where were your offices?   Were you in the South Building?


Mr. Cromartie:
In the South Building.
                                                             3

Mrs. Whitaker:
There were so many years that Insecticide wasn't even
a Division.     Was it a Division during those years after
it went back to Agriculture?



Mr. Cromartie:
The way I remember it was this.     Sections, Divisions,
and Branches switched from one to the other and you
didn't know what you were.     You could have been a Section
at one time and had as much authority as a Division
later on.     Division, I guess, right now is the highest.
No, the Branch is the highest, then the Divisions, then
the Sections.


Mrs. Whitaker:
From the records, I had the impression that the Department
of Agriculture didn't really know what to do with you
people after 1940.


Mr. Cromartie:
That is correct.     When they took Food and Drug out of
Agriculture, they didn't have anywhere to put the Insec­
ticide Division.     Someone came up with the idea that ~e
had dealings with livestock preparations so that's where
we wound up.     We had about the same problem with the
Livestock Branch as we did with all the rest of them.
They didn't know anything about the work.     The strange
                                                            4

thing about it, until they started raising cain about
residues, Agriculture didn't have too much interest.
When Ribicoff started investigating and all the rest
of them, we got in the headlines.   ARS at that time
realized that it was more important than they had actually
figured.


Mrs. Whitaker:
But it wasn't really until consumer pressures were put
on • • •


Mr. Cromartie:
That's right.    It really started branching out when the
new act was passed and the new insecticides and fungicides
started coming on the market.    They just had to spend
more attention with it.


Mrs. Whitaker:
Concentrating for just a little while on the personalities,
people that you worked with • • •    Tell me about Dr.
McDonnell.   I find very little on him as a person.


Mr. Cromartie:
You're going to have to censor some of this stuff.


Mrs. Whitaker:
We can take it out.
                                                             5

Mr. Cromartie:
He was very easy going.     Dr. Griffin was the key to the
whole thing.     Of course Dr. McDonnell was chief of the
Division but Dr. Griffin was the one that actually knew
the background of the work and was familiar with all
angles.    He had knowledge of bacteriology, insecticides,
and fungicides altogether.     He had been in the laboratory
before he became assistant chief.     I would say that he
knew more about the Act and its workings than anybody
before or after.


Mrs. Whitaker:
Now, this was Dr. Griffin?


Mr. Cromartie:
Yes.   In fact, he practically wrote the insecticide act
of 1947.     He answered all the questions, he handled the
industry, in conferences,     They had certain objections
that they didn't want in it.     He practically brought the
Act to its final fonn with the objections of industry
corrected.     At that time, industry had quite a power
and we couldn't be too hard on them.     In other words,
they didn't want you to jump out and start cleaning up
everything.


Mrs. Whitaker:
Was there any pressure from environmentalists or consumer
groups?
                                                              6

Mr. Cromartie:
There wasn't any such thing.     I never heard of them before.
I don't remember anybody ever representing consumer groups.
There wasn't any such thing as residues at that time.
DDT, chlordane, heptichlore and the herbicides weren 1 t
even on the market.     They hadn't even been developed.


Mrs. Whitaker:
Food and Drug was getting all of the flack about the
arsenical residues on fruit?     You really didn't have
anything to do with that, did you?


Mr. Cromartie:
The only residues that I remember--and I'm sure I'm right
on that--the residues they checked for were lead and
arsenic.   I've picked up hundreds of samples, fruit and
that stuff, where they were checked for lead and arsenic.
Those are the only residues that I know of at Food and
Drug.   After the new chemicals started coming in and it
was found that they could be harmful, Food and Drug had
to branch out on their residues.     Up until   1   45 or later
there wasn't any such thing as residues, except lead
and arsenic.     At that time they did a lot of checking
on lead and arsenic.     You'd get it in your food products,
maple syrup for instance.     They'd have the sap buckets
painted with white lead paints.     Syrup has a great affinity
for lead, particularly, and when the sap was concentrated
                                                              7

down to about 20 to 1 or 40 to 1.


Mrs. Whitaker:
Where were you stationed in '35 or '36?


Mr. Cromartie:
In '35 I was in Los Angeles.       No, up until about the middle
of   1   34 I was in Los Angeles and then from '34 to '37 I
was in San Francisco.


Mrs. Whitaker:
Then, in both stations, you would have had associations
with the lead arsenate residue on fruit coming out of the
Northwest?


Mr. Cromartie:
In those days we would set up stations in various parts
of the West and we would stop trucks as they would be
leaving Colorado and going to Texas and take samples.
And there was a chemist there and we would test the samples.

By the time the trucks got to their destination we knew
whether the crops had excessive residues on them.       We
didn't have any authority to stop those trucks.


Mrs. Whitaker:
That's a matter of public record, I think.
                                                             8

Mr. Cromartie:
I worked at some of these quarantine stations in Arizona.
They were the only ones that had them at that time and
we would stop trucks there.     I would ship the samples
in.   We would check the manifest to see where it was
going.   The samples went back to the laboratories and
they were checked for residue.    Of course, by that time
the produce was already gone.     Produce goes in at about
two or three in the morning and it's gone by ten.


Mrs. Whitaker:
The Secretary acknowledged during that period that there
was little authority for setting a residue at all.      That
was the big problem in the 1938 food law.     They did want
some method of setting a toleirance because before then it
was simply an administrative act?


Mr. aromartie:
You had to settle each case in court, if they contested
it.   We brought a trial case in Vermont with maple syrup
with lead in it.   We lost the case.    If you get a jury
in these states where maple syrup or something else is
produced, you can't win them.     But it w~s a test case.
The last I remember lead and arsenic were about eight
parts per million and they had been lower· than that at
one time.    They kept changing them until more research
developed.
                                                                 9

Mrs. Whitaker:
Did you testify in any of the court cases?        I was parti­
cularly concerned with fruit.    Did you testify in any
of those cases?    Were you in the courtroom, for instance,
when the case against the Washington Dehydrated Apple
Corporation ••••••••••••••••


Mr. Cromartie :
I was at the maple syrup case.     I don't remember but one

or two that I testified in.     In other words, if there
was a clear cut case, they wouldn't argue.        When something
new came up--dehydrated food or maple syrup--industry
would fight something new that way but something that
was established they would just    go   ahead   and   either plead
guilty or nolo contendere and let the judge settle it.


Mrs. Whitaker:
Dr. Griffin had also mentioned the difficulty of getting
a court decision where a jury heard the trial.          Was it
really difficult for you to win a case if it went before
a jury?


Mr. Cromartie:
Yes.


Mrs • Whitaker :
Were the juries hostile to government?
                                                          10

Mr. Cromartie:
Yes.     They were invariably, particularly when you picked
them up in the area where the industry was located.      The
Food and Drug lost a case up in North Georgia before I
went in.     The Food and Drug man that interviewed me was chief
of the Savannah station then and came down home.      He was
telling about a tuberculosis cure in the mountains of
North Georgia that the government lost.     It was a jury
trial.     You have some juries that way that have a strange
viewpoint.


Mrs. Whitaker:
I think some of your notices of judgment would indicate
that.


Mr. Cromartie:
I think we had the largest fine in the Insecticide Division
at that time on a disinfectant manufacturer in Baltimore.
I think it was $5,000.     He pled nolo contendere.   It was
hard to get a case into court, believe it or not, even
through the office of the General Counsel.


Mrs. Whitaker:
Why was that?


Mr. Cromartie:
We were not important.     I sent cases down to the office
                                                          11


of the General Counsel at the time I was there and they
just wouldn't file them.   They kept putting them off; they
didn 1 t have the clerical help, etc.


Mrs. Whitaker:
I think the records pretty well indicate that it was
difficult to get cases on the docket.


Mr. Cromartie:
We sent cases down that were clear cut.   They just fiddled
around and never did file them.    I got so mad at one time
I told them I wasn't going to send any more down.    It
took a lot of work working up those cases.    When we sent
them down, all they had to do was write out informations
and file them.    Of course, they had to go through the
channels but they were pretty hesitant about it even
up to the time I left.


Mrs. Whitaker:
Some of these cases would take seven years to get before
a judge.


Mr. Cromartie:
And a judge isn't going to look very kindly on a case
 like that.   I know we got some strange cases of these
federal judges.    They're powers in themselves so they
don't have to worry.
                                                             12


Mrs • Whitaker:
You mentioned the disinfectants.       That was one of the
things I did want to talk about because it seems almost
ironic that more of the cases that did reach the court
involved disinfectants rather than agricultural insecti­
cides.   And you found this to be true even after you
joined the Department in 1931?


Mr. Cromartie:
One reason I think is that at that time the manufacturers
could control the output much easier.       In other words, if
you are making a 50 per cent lead arsenate dust, all you
have to do is weigh up half with filler and half with that
and mix it thoroughly.      A   lot of violations resulted from
poor mixing.       Either that or they would get too much of
an overrun on the product.       As a whole, agricultural in­
secticides were pretty well controlled.        Not only that,
there was another reason for it.        The states spent more
time on the agricultural insecticides than they did on
the disinfectants.       The fact is, a lot of the states
didn't have laws to cover the disinfectants.


Mrs.   Whitaker:
And so that became a federal jurisdiction?


Mr. Cromartie:
Yes.
                                                          13

Mrs. Whitaker:
While the Insecticide Act was with Food and Drug, do you
think the fact that disinfectants are so closely related
to medicine influenced the emphasis on disinfectants?
Do you think that Campbell was more interested in disin­
fectants?


Mr. Cromartie:
No, I don't think so.    The whole reason was that the dis­
infectants the Insecticide Division covered were for use
on inanimate objects.    Food and Drug had the germicides
and that type for human use.   Another reason is that dis­
infectants are very competitive.    There was a high profit
in them.    Some of the manufacturers.were very unethical
in their dealings.    You'd go to these counties, in the
South particularly, where the sheriffs did the buying
and the salesmen would make kickbacks.    The margin of
profit was so high that they didn't have to worry, back
in the early 'l~O' s particularly, and they would give
away shotguns, traveling bags, or anything else in order
to get the orders.    You could almest tell when you went
in a county office the way they reacted whether someb:ody
got a kickback or not.    They were very hesitant about
your sampling the material.    It was explained to them
that we weren't interested in anything but the fact
that they got what they paid for.    Once it was explained
to them, they weren't nervous at all.    There was a lot
                                                           14

of competition, there still is.


Mrs. Whitaker:
You picked up a complete range of products?


Mr. Cromartie:
That's right.    You had to.   You had the whole area.


Mrs. Whitaker:
Was a project type thing assigned to you?     Would you be
advised what kind of product to sample at a particular
time?



Mr. Cromartie:
No.     The inspectors were on their own in the field.    We
would get assignments from Washington on follow-ups.
They might have a product that was marginal and they'd
want an additional sample of it.     The inspectors, in
checking the plants, would have shipments going out of
their territory.     With our correspondence between the
inspectors, they would send over shipments for me to
cover in New Orleans that were shipped from Chicago.
Other than that, we had our sampling manual and anything
in that that hadn't been covered we would sample.        Now
for each territory, the inspector was responsible for
his produc·ts.    If I picked a sample from an Atlanta manu­
facturer and the schedule called for only one sample
                                                          15

of that product from each manufacturer, then that was
written off and I wouldn't bother with that until next
year.   We got roost of our leads from checking the shipping
records in the manufacturers' plants.    We didn't have
authority to do that either until the new Act.


Mrs • Whitaker :
In the period before the Insecticide Act went to Food
and Drug, Haywood did not use factory inspection.    It
wasn't until Campbell took over that insecticide inspectors
went into the factories.    I'm not sure why Haywood would
not use factory inspection.    Do you know anything on that
• • • why he refused to let his inspectors go into fac­
tories?


Mr. Cromartie:
I can tell you this, in my opinion factory inspections
were of little or no value at all.    It wasn't like Food
and Drug.   They can take action on filth conditions and
close up a plant on it.    On insecticides and fungicides,
the condition of a plant had no bearing on the composition.
I know under the Food and Drug I spent hours making factory
inspections and writing them up.     I made some that would
take a week to write up.    We did it on overtime mainly.
We didn't have the time, you had your assignments during
the day.    As far as I know, under the Food and Drug Act,
other than the shipments, I don't know what value they
                                                              16

were.   We cut them out when I got to Washington.       They
don' t do it now, I don' t think..    It was time wasted.    In
other words, we were only interested in the product that
reached the consumer.    They could take any kind of mixing
equipment, some of it is very simple.       You can take a
steel drum and put a motor and a pulley on it and make
as good a mixture of an insecticide and some as well as
these million dollar corporations.       It takes more time
and you don't have the volume.       That's the only difference.


Mrs. Whitaker:
When Insecticides went back to Agriculture in 1940, what
was the practice in those first years?       Did you continue
factory inspections when you took over?


Mr. Cromartie:
We didn't have time.    We only had five inspectors at one
time and we had to keep the laboratories occupied.          At
that time there was a laboratory in San Francisco, one
in Chicago, one in New York, and one at Beltsville.          Soon
after I was transferred to Washington, due to funds, and
the Livestock Branch was actually the reason, Harry Reed
figured that we didn't need the one in San Francisco
and the one in Chicago and they were closed out.        And
the personnel--they only had maybe one chemist or two
at each station, they did all the analytical work in
New York and Beltsville.     They just closed them.
                                                           17

lack of funds, the main thing.     They've never opened
them yet that I know.     They still have the one in New
York, I imagine, and the one in Beltsville.     When you
have five men in the field, even if factory inspections
had been of any appreciable value, we wouldn't have had
time anyway.     We visited the plants where they were making
the products and checking the records but we weren't too
interested in the manufacturing process.     We did do a lot
of sampling at the plants.     That was because we were checking
the materials that they got that they were mixing.        In
other words, it was to their advantage for us to do that
because if a manufacturer sold them a five per cent dust
concentrate, like Rotenone or pyrethrum and they were
short changed, when they made their products their materials
would check short.     And that was the excuse that many
of them used, that their raw material was deficient.


Mrs. Whitaker:
The old Act covered raw materials, I believe.     You could
bring suit against the manufacturer of the raw material?


Mr. Cromartie:
If it was shipped interstate.     Now, of course, raw material
in itself isn't very descriptive.     By that tenn we'd mean
a product that was further processed.     Some of it you
could use itself, as it was, if you wanted a concentrate.
You could use straight Rotenone powder or straight pyrethrum
                                                           18

powder.   But it was too expensive and it was only for
certain uses.     So a raw material, in the terms I am using,
just means something that was to be further processed.
It was an insecticide in itself.     Otherwise we couldn't
have covered it.


Mrs. Whitaker:
As we approach World War II, the emphasis again was on
increased production.     Were you in any way instructed
to cut back on the amount of inspection that you did of
agricultural products or insecticides for agricultural
use?


Mr. Cromartie:
No, it didn't make any difference as far as I know.
The fact is that as far as the war was concerned the only
handicap it had with us was traveling conditions and
things like that.


Mrs • Whitaker:
You continued the same kind of projects?


Mr. Cromartie:
The same routine that we had.


Mrs • Whitaker:
You mentioned a case in Baltimore on a disinfectant.
                                                          19

Did you testify in that case?


Mr. Cromartie:
No, I didn•t testify.   We presented the facts.   They pled
nolo contendere.   We explained the case to the judge and
that was all that happened.     There wasn't any testimony
except what we gave.


Mrs • Whitaker:
Very seldom did the courts impose any kind of jail sentence,
though that was possible under the Act.    What was the
feeling from the administrative standpoint concerning
jail sentences?


Mr. Cromartie:
As far as I know, they weren't too interested in jail
sentences.   The type of violation was more of an economic
cheat and not a health hazard.     Of course, under the new
Act that made it different.     I don't know whether anyone
has been sent to jail or not.


Mrs. Whitaker:
Can.iyou pinpoint the time at which judges became a little
more exacting in what they imposed in the way of fines?


Mr. Cromartie:
The more publicity insecticides got, the more the judges
                                                             20


became conscious of them.     We had a case--it was a Baltimore
judge--where he'd never heard of the Act.      He said that.
But he didn't hesitate to fine them.      Maybe that's one
of the reasons that he did it.      He was used to cases under
Food and Drug in which there were health hazards involved.
He fined them more than we expected.      We would have been
satisfied with a two or three thousand dollar fine.      We
had never had one that large before.      That kind of threw
the fear of God in the manufacturers.      They know everything
that goes on.      Not only that, they take the notices of
judgment around to their prospective customers and show
what·:their competitors are in violation of.     They would
do anything to sell merchandise.


Mrs • Whitaker :
I wondered if manufacturers might object to the notices
of judgment from the standpoint of publicity?


Mr. Cromartie:
They didn't like it at all.      They would admit that they
would rather pay a thousand dollar fine and forget the
whole matter.      But the law didn't read that way.   These
cases had to be published in some form or other.       I'm
just wondering now how they publish them.


Mrs. Whitaker:
I noticed in some of Haywood's correspondence in the
                                                          21


early cases that he was frequently frustrated by what he
considered incompetence on the part of the federal attorney
who would be handling the case because he didn't know
anything about the law.    Did you find this to be a problem
when you


Mr. Cromartie:
It was and probably still is.    We would go in when we had
a case to the U.S. attorney's office and try to explain
the case so that they would know.     They were completely
ignorant of the Insecticide Act in most districts.     Some
of them might never have had a case.     We would go in and
have a conference with them and explain the case and then
they would get a different viewpoint on it.     On this case
in Baltimore, Miller of the Office of the General Counsel
and I had conferences with the U.S. attorney's office
and explained the background of the firm and the violations
involved.


Mrs. Whitaker:
That's Lowell Miller?


Mr. Cromartie:
Yes, Lowell Miller.     He was the one that handled the cases.
We talked with the assistant down there that was going to
handle the case several times.     We had the case in good
shape.     There were several violations involved.   It was
                                                           22

cut and dried.    We still had to present it to the judge
so he would understand it.    He said he had never heard
of the Act so it didn't make any difference in that case.


Mrs. Whitaker:
I read one case in which the judge had charged the jury
with having to consider the intent of the manufacturer
to defraud.   Apparently he confused the Food and Drug
Act with the Insecticide Act.    You did not have to prove
the intent of the manufacturer under the Insecticide Act?


Mr. Cromartie:
That must have been an old case.


Mrs. Whitaker:
It was an old case.


Mr. Cromartie:
I'll tell you why.    It was a case of fraud.   In fraud up
until the new Food and Drug Act went in, it was difficult
to prove fraud.    It's difficult now.   Even in income tax
cases they have a job doing that.    Of course, the 1937
Food, Drug and Cosmetic Act corrected that.     But before
'37 they had to prove intent.    That was never in the Insec­
ticide Act.


Mrs. Whitaker:
In this particular case the judge was confused and every-
                                                           23

thing the United States attorney did failed to convince
him that it was not necessary to prove intent under the
Insecticide Act.    The solicitor in the Department of Agri­
culture was extremely concerned that they had lost this
case.   They tried for seven or eight years to convict
this particular manufacturer.


Mr. Cromartie:
I bet he was from Baltimore.


Mrs . Whitaker :
I am not sure.


Mr. Cromartie!
He was a character.     I never did see him.   Dr. Griffin
discussed him.     The funny part is that he was right.
He came in with a cane and a top hat and long coat.
If it's the one I'm thinking about, it was a one-spot
flea killer for pets--dogs and cats--and the way he got
the idea for the name none spot" was that you put it
on the back of their necks.     That 1 s where the fleas con­
centrate, on the back of the neck and the back too.
His argument was that fleas moved up towards the head,
which they do.     They never did get it off the market,
if that was the case that I'm thinking of.      It could
have been one that was very similar.     They never did
get it off the market.     It's still on the market and
                                                          24

labeled properly.


Mrs. Whitaker:
They had a lot of problems also with systemic insecticides.
Under the old act, some of these were out-right frauds
I would suspect.    Do you recall any of these cases where

they simply put a tablet into the poultry drinking water,
for instance, and it was supposed to take care of lice
and mites?


Mr. Cromartie:
They had those--I think it was potassium permanganate
tablets that they used a lot in the drinking water--which
were effective under certain conditions.    We had very
few poultry and livestock violations.     There weren't too
many manufacturers and most of them were pretty reputable.
There weren't too many large companies.     Of course, you
would run across the shysters that would bring     up a new
product on the market and rush it through and it would
be ineffective.     I don't remember a single case of live­
stock or poultry violation that we had.     There are bound
to have been some but they didn't wind up in prosecution.
We'd have citations and seizures.


Mrs. Whitaker:
What years were these?
                                                         25

Mr. Cromartie :
In the 30's I think.


Mrs • Whitaker :
Did you deal much with the cattle dips that the Bureau of
Animal Industry would have been concerned with?


Mr. Cromartie:
Yes, the BAI had at that time a list of permitted dips
and disinfectants that they didn't approve but they accepted
them.   They had previously tested them.   We sampled those
the same as the rest of them.   We did have violations
on those but none went to court.   Maybe we'd seize them
but we never prosecuted.   You see, if a manufacturer had
a permitted dip and disinfectant, he wanted to maintain
a standard Qn'.it because it was a selling point.   In other
words, BAI would use it.    If there was an accepted dip,
then a firm would have a much better chance of selling
it to somebody that wasn't with the government.


Mrs • Whitaker:
You mentioned seizures.    Haywood had tried seizures to
some extent in the early period, not with a great deal
of success however.    But after Insecticides came under
the Food, Drug, and Insecticide Administration in 1927
Campbell increased the number of seizures.    What was
the practice after you came in in 1931?    Were you using
                                                          26

multiple seizures to any extent?


Mr. Cromartie:
Oh, yes.   They still use them,unless they've changed.
In other words, as I remember it, the courts held that
the government could make multiple seizures on certain
violations.   On the economic cheats they had to settle
one before they could make others.    In other words, this
one had to be settled in court before they could make
others.    But on the health hazards there wasn't any limit.
We made multiple seizures all the time.    In other words,
there isn't any reason why if this wholesaler has 500
cases of a product that's deficient--somebody's going
t-o get gyped or get ineffective material--and another

fellow over here has the same amount or half the amount
and it is deficient, both of them should be off the market.
Not only that, you take a large produce grower, if he
gets an inefficient product it can hurt him.


Mrs. Whitaker:
You mean as far as not protecting his crop?


Mr. Cromartie:
Yes.


Mrs. Whitaker:
With the old arsenicals, not only were the crops not
                                                         27

protected but sometimes the products actually damaged the
vegetation itself.     Was that one of the concerns that you
had?


Mr. Cromartie:
That was on the basis of water soluble arsenic.     On all
the arsenicals they had to state the percentage of water
soluble arsenic.     If there was too much soluble it would
burn the crop badly.     They had a lot of cases like that.


Mrs. Whitaker:
Did you see much of that yourself?


Mr. Cromartie:
We never came in contact with it too much.      They could
have had it; we wouldn't have known about it.


Mrs. Whitaker:
Your contact was almost exclusively with the manufact1,'ll'er
and distributors themselves rather than the consumer?


Mr. Cromartie:
We contacted the consumer a very small percentage of the
time.   There'd be a lot of direct shipments.    A consumer
will get maybe two or three packages or something like
that.   What we tried to cover were the large lots, the
distributor or wholesaler.     On some products where there
                                                            28

was a very small amount made and shipped we would contact
the user.     If a user got one container it was generally
open so you had to have an unopened container.     You had
to have at least more than one container before the sample
was of any value.    We couldn't prosecute on open containers
but we could seize and we did take opened drums of pyrethrum
powder, etc.     It could be opened--it might be 200 pounds-­
and it might be deficient and the manufacturer had used
part of it.     If the sample was deficient, we would seize
the remainder because the value justified the seizure.
We didn't ordinarily seize on a shipment unless it was
$100 or $250.     In other words, you had to figure your
court costs.     It may not be worth it.   If there is no
hazard involved, it is cheaper for the tax payer to let
it go.


Mrs. Whitaker:
Especially in view of the trouble you had getting appro­
priations?


Mr. Cromartie:
Not only that, on an open container you ran a chance of
it being used before you could get to it.      It would take
a couple of weeks for a seizure to go through once it
was analyzed.    We had to write up the recommendation
which covered the violations and then send it around
to the office of the General Counsel and they would have
                                                            29

to write up the libel and then it had to go to the U.S.
attorney in the district where it was located.     He had
to file it and then it had to go to the U.S. marshal.
I don't believe it would go through in two weeks unless
it was a very urgent situation.    It was a pretty slow
procedure.


Mrs. Whitaker:
You mentioned the division being a sort of a step-child
to the department after it reverted in 1940 to the Depart­
ment of Agriculture.    Did you have trouble during those
years getting appropriations adequate to your needs?


Mr. Cromartie:
Harry Reed was chief of the Livestock Branch at that time
and he was the one that brought Webster Reed in.     They
weren't related.    He didn't know anything about it. Many
of them felt that Dr. Griffin should have been appoihted
chief and Harry Reed did say later, I heard, that if he
had known to start with what he did, Dr. Griffin would
have been appointed chief.     Dr. Griffin didn't have the
personality; he had the knowledge.     He was blunt at times,
I guess.     He understood the background of it and so he
didn't hesitate in telling or expressing his views.
Webster Reed came over in 1944.    All of them had to depend
on Dr. Griffin.
                                                             30

Mrs • Whitaker :
From some of the correspondence I have the impression that
Dr. McDonnell had more or less groomed Dr. Griffin to be
his successor.


Mr. Cromartie:
Not only that, when Dr. McDonnell retired everybody thought
that Dr. Griffin was going to be appointed, but he wasn't.
I don't know the reason for that.      I've forgotten.   John
Coyne was never chief of the Division.      Dr. Griffin retired
in 1955 while Dr. Reed was still chief and Coyne was
brought in as Dr. Reed's assistant.       He (Coyne) later
went back to Packers   &   Stockyards as administrative officer.
I think. Dr. Griffin retired as early as he did because
he was not made chief of the Division.      When Dr. Reed
retired, Mr. Ward was made chief and remained so until
Dr. Hays ca.me in which was about May 1965.      I retired
December 31, 1966.     White was Mr. Ward's assistant.
I think Dr. Griffin was about 65 when he retired.        All
he had to do was sit up there and answer questions.
He knew the answers.       He used to drive me nuts sometimes
on these seizure recommendations and notices of judgment
and prosecutions.    I had to write them up.     There were
only three of us there.       He went in for commas and every­
thing, and charges had to be just right.       So I finally
got where I could think like he did so then I'd send
them up and they'd go through.       I had to learn to think
                                                            31

the way he did.    I learned more from him on enforcement
work than anybody else.     He just knew it, that's it.
Back in those days, they were more accurate.     I don't
know why.    I don't think it served a purpose, but it must
have.


Mrs. Whitaker:
This was the mid-40 1 s you are talking about~


Mr. Cromartie:
Yes.    Every comma had to be right.   You had to quote labels
in the charges and sometimes you'd have two pages of a
label to quote.     He would check t~ose labels just like
they were printed and if there was a comma omitted, he
would send it back.     I don't think it made any difference
at all.     Of course, when you messed up a charge as it
should be, that's entirely different.     That's the only
way I ever learned to write them up without them bouncing
back two or three times, was thinking like he would.


Mrs. Whitaker:
In the chain of comm.and, did you have much association
with the Secretary of Agriculture or were you so far
down the • • • ?


Mr. Cromartie:
We were too far down.     Maybe once in a blue moon.   I
                                                                 32

sometimes think the Secretary didn't know anything about
the Insecticide Act either.          But you see, at that time,
ARS, at least at the end, was over the Insecticide Division
as well as all the others.       So the head of ARS and his
deputies were the ones we had to deal with.          The Secretary
would only come in when some Congressional committee would
start investigating or Agriculture would start.          The last
two or three years I was there I think. we spent most of
our time writing up reports either for Ribicoff or the
Secretary.     There'd be complaints, kicks, and everything
else.   In the last one--to give you a good example of
that--the records were in the office at Washington.
Ribicoff spent months investigating the Insecticide
Division, got all this publicity, but in the end when
they wrote out the report in about three volumes, about
one inch thick, hardback, the Insecticide Division was
cleared.     They 1 d enforced it.     They'd done what they
were supposed to but nobody ever heard of that.          So we
spent about half our time furnishing infonnation; somebody
was always up there.


Mrs. Whitaker:
This was after the new act in '47?


Mr. Cromartie:
Yes, this was just three or four years before I retired.
And then they weren't satisfied with that investigation.
                                                                33

The Secretary appointed a committee to investigate, that
was about a year and a half, I guess, or two before I left.
They appointed Dr. Hays as chairman of it and then they
had several state people.         They didn't have anybody from
industry that I remember.         They spent two or three months.
Dr. Ward retired soon after that and then Dr. Hays, the
chairman of the committee, was appointed head of the In-
secticide Division.    It is      my   understanding that he's been
pushed upstairs now.    He was with the National Academy
of Sciences at the time.


Mrs. Whitaker:
The time at which he began the investigation?


Mr. Cromartie:
Yes.   But of course when he was appointed chief of the
Division I guess he'd have to get out of it.           But he
didn't know much about it.         Then everything was breaking
down and there were a:•lot of headaches on residues and
stuff like that.   So he was in a year or so before I
retired.   He was very easy to work with.          I never worked
with anyone that I enjoyed more.           I guess one reason
that he didn't bother me, he didn't know enough about
it.    I always said I was going to get out as soon as
I could, even back in   1   31.
                                                               34

Mrs. Whitaker:
You had some 30 years.


Mr. Cromartie:
No.     I had over 35.   But the pressure was getting too
much.     I mean, it was Sundays, Saturdays, nights, holi­
days; you just had more work than you could handle, that
was the whole thing.      We were understaffed.    Now they
have about three people doing what one used to do before.


Mrs. Whitaker:
How many inspectors did you have under your supervision
at the time that you retired?


Mr. Cromartie:
About seventeen, I think.       There at the end we brought
in five or six in one year.       I spent a lot of time traveling,
interviewing them.       We got most of them from Food and
Drug.     There were several reasons for it.      They had a
lot of inspectors that were dissatisfied, as many as
they have, some are bound to be dissatisfied.         It would
take two or three years to train a new man if he'd never
had any experience and maybe $50,000 if you start figuring
time and all.     I knew them all anyway at one time or other
so when we wanted a new inspector we 1 d have the inspector
in that area inquire around who wanted a transfer and
we got all we wanted already trained.
                                                         35

Mrs. Whitaker:
Were the salaries commensurate?


Mr. Cromartie:
They were the same.    Some of them are probably making more
now than they would have had they remained with Food and
Drug.


Mrs. Whitaker:
When you took over the administrative part of the inspection
you had only five or six men?


Mr. Cromartie:
Five, if I remember correctly.     I'm sure it was five be­
cause we had San Francisco, Chicago, Baltimore, New York
and Atlanta.     At that time they had an assistant in New
York and then when I was moved to Washington, we moved
him to Atlanta, and we still had five.


Mrs. Whitaker:
Were you subjected to much pressure from manufacturers
as far as not prosecuting a product that you knew was
in violation of the law?


Mr. Cromartie:
Not at all.    The way it operated is this.   When a violation
occurred, we would issue what we called citations.     That
term is incorrect.    They were actually notices of violation,
and they had an opportunity to come in,.and show why they
shouldn 1 t be prosecuted.   Or they could answer by mail.
The larger ones would come in but the smaller manufacturers
would tend to have their attorneys answer the charges.
Most of them had some kind of excuse.      One of the common
ones was that the superintendent of the plant was res­
ponsible and he is no longer with them.      That got to be
a joke.    The main purpose was to give an opportunity to
show why they shouldn 1 t be prosecuted.    If we made a seizure,
they either had to let it go by default, take it out under
bond and reprocess it, or contest it.      After that we would
issue a notice of violation on which you could prosecute.
As far as I know, there never was any problem at all on
that.     There wasn't much pressure they could bring.   It
was seldom ever done.     Towards the end we had one or two
that they'd fight but the way I remember it, they lost.
One of the well known rodenticides .•.•••••


Mrs. Whitaker:
Was this under the new Act?


Mr. Cromartie :
Yes.    The old Act didn't cover rodenticides.    We would
have maybe fifty or sixty citations a month, and maybe
twenty-five or thirty seizures.     It would vary.   From
there on it would depend on the background of the case
                                                            37

in how far you were going and the reasons they gave why
they shouldn't be prosecuted.


Mrs. Whitaker:
Some of the charges that were brought against the Depart­
ment in the more recent years, after the 1947 Act was
passed,ms that manufacturers could put political pressure
through their Congressmen upon the Secretary perhaps to
not prosecute a product.     What is your opinion ••••••••


Mr. Cromartie:
I never had that experience.     We would have cases like
this.     We'd have a violation and the fellow would write
his Congressman and his Congressman would call us up
or something and then we'd go up and talk to the Congress­
man.     It never changed our recommendation one way or the
other.     Those cases were very few.    We had the cases
pretty well under control.     We weren't getting out on
a limb, really, because we were too small.       We couldn't
afford to.     It was bad enough when you had a prosecution
and lost it, much less bringing it when it was not jus­
tified.     I would have thought that the objection most
people would have had was Dhat we didn't prosecute enough,
and I think that came out later.        I know we didn't prosecute
enough.     But we didn't have the personnel and the cases
weren't too important.     The U.S. attorneys and other
factors were involved.
Mrs. Whitaker:
When you say the cases were not too important, do you mean
not too important to the consumer?


Mr. Cromartie:
No, to the Justice Department.


Mrs. Whitaker:
So, if there was a delay or if the suit was not prosecuted,
then it might sometimes be because the Attorney General's
office did not follow through?


Mr. Cromartie:
They had the more important cases.    An insecticide case
in a district court wasn't a drop in the bucket, really.
They had so many important cases that they had to handle,
and there was probably more publicity to them than to an
insecticide case.


Mrs. Whitaker:
You had already mentioned that even the solicitor's office ••.••••


Mr. Cromartie:
They were slow in filing them.     I don't know whether I'd
want that in print or not.     I told them that.   I told
them that several times.     They had legitimate excuses.
They didn't have the help and they had more important
                                                           39

things too, I guess.


Mrs. Whitaker:
So there really wasn't any pressure put on them to carry
through on some of the things.


Mr. Cromartie:
There should have been.     We'd call them up--"When are
you going to file this?"     "we   haven't gotten to it yet."
George is in the Insecticide Division?


Mrs. Whitaker:
Yes.   He's with the EPA now.


Mr. Cromartie:
And Lowell Miller is too, I guess.      Miller came over
before I left.     Miller wanted to get in a long time ago.
And White, incidentally, getting back to that, was one
reason I think he didn't get in earlier.       He got in after
Dr. Hays got in.     I recommended him to Dr. Hays and Dr.
Hays had him over and interviewed him.       He impressed him
very much.


Mrs. Whitaker:
This is Lowell Miller?


Mr. Cromartie:
Yes.   Way back Lowell wanted to transfer to the Insecticide
                                                           40

Division and I mentioned it to Mr. Ward.     White said we
didn't need any more lawyers up here with you to handle
enforcement.     Of course Miller would have been handy to
have up there because of his legal background.       I didn't
have any legal background except experience.     Somebody
could have passed on these legal questions before they
got down there to the solicitor's office.     We never had
any problems with them because we worked so closely to­
gether.     I don't know what Miller is doing now.


Mrs. Whitaker:
He is not in General Counsel.


Mr. Cromartie:
I was in Washington a month on business about two or
three years ago.     They had built some new offices down
there since then.     I know from what I've heard that they've
got it pretty well scattered now.     Of course it's getting
so big.     I know in Atlanta there I called up the old office
in Decatur last July, I think I was in Atlanta, and a girl
answered the phone.     I asked her where the inspector in
charge was and she said he was in an office downtown in
Atlanta.     I didn't even know they had two offices.    When
I was there we had the one in Decatur.      I only hear from
them about once a year; I hear from several of the in­
spectors.     They bring me up to date.   I've never actually
gotten a full run of how they're operating now except
                                                            41

that they are a whole lot larger than they used to be.


Mrs. Whitaker:
Speaking of how they operate, would you tell me something
about the changeover in 1947, how your responsibilities
changed and what problems presented themselves after you
became responsible for registration of products?


Mr. Cromartie:
No, it was mainly a title really.     They set up a branch-­
they had a division and a branch and then the sections.
When they decided to set up a branch, they asked Mr. Ward
who to make head of the branch.     He said I was the only
one that he could think of so I was made branch chief of
registration and enforcement.     I couldn't even handle
enforcement really.   I mean, I had more than I could do
there.   He let White, his assistant, supervise registration.
Of course we had a section chief in registration, who had
formerly been my assistant.     In fact, he was the first
one I brought in after I got to Washington.     He was made
the head of registration.     They operated pretty much on
their own.   You didn't have any problems.    The labels
went through and it was a clerical process really.     Most
of the time we had to spend was on enforcement.     Regis­
tration took care of itself.
                                                          42

Mrs. Whitaker:
What were some of the first problems in enforcement after
the law went into effect?


Mr. Cromartie:
We actually didn't have any problems.   The problem was
personnel and funds.   The operational procedures were
perfect.   You didn't have so many inspectors and you knew
each one of them personally.   You talked to them on the
phone if anything came up, and there wasn't any problem
except overwork.


Mrs. Whitaker:
Did you change the procedure any as far as the kind of
projects you wanted the inspectors to work on?   Did you
assign projects to the different inspectors in the dif­
ferent areas?


Mr. Cromartie:
We would send out assignments from Washington.   More of
them went out at the end than at first because there were
fewer products to start with and later there were literally
hundreds of them.   You couldn't cover all of them really.
After the new act came in we had to write a new manual.
It changed everything completely.   Number of samples,
type of products you had to concentrate on, things like
that--so we had to rewrite the manual and sampling pro­
cedures.   After the new act went in, the volume was such
                                                         43

that what we did before was a picnic.


Mrs. Whitaker:
What was your reaction--this would have been during the
war years--to the new products as they became available
commercially?    With DDT for instance, did it require any
different procedure?


Mr. Cromartie:
We had to work out new methods and everything else.    They
got so involved and they developed so many new methods
that they just had to keep working all the time.


Mrs. Whitaker:
Do you think your inspectors realized the significance
of the new products that were coming on the market?


Mr. Cromartie:
Yes.   We'd hold conferences in Washington at least once
a year.   And I would get out in the field on trips and
we kept them up to date pretty well that way.    Their main
problem was to cover their territory--that is, cover the
products manufactured in their territory--and send in
representative collections of what was manufactured in
their territories.     In other words, they couldn't stick
to disinfectants which they wouldn't because they were
so hard to sample, drums and that kind of stuff.     They
                                                        44

couldn't limit their operations to just a few products.
They had to give it a pretty comprehensive coverage for
their territory.    Now they have such small areas that they
can do it.   But then it was a job with the limited number
of inspectors that we had.


Mrs. Whitaker:
It must have been a problem, especially in the Southeast
where you had vegetable crops, cotton, fruit.


Mr. Cromartie:
I've covered the six Southern states from '41 to '45 and
we had such a variety of products down here that there
wasn't any limit to the number of samples you could collect.
I remember one year I collected 499 samples in one month.
That's the most I guess that's ever been collected and
ever will be now the way they operate.    I figured on 500
but I counted wrong at the end of the month.     But I didn't
do that often, it was killing~work.    That was in Florida,
incidentally.    I would get to Florida somewhere around
the middle of January and leave after April 1st or April
15th and then I'd go back to Atlanta for maybe a month
and then I'd start out for other parts of Georgia, South
Carolina, Mississippi, Alabama, and Louisiana.     You hit
a town like New Orleans, you could spend a month there
and not cover it.
                                                        45

Mrs. Whitaker:
What did you do?   Did you go to feed stores?


Mr. Cromartie:
Feed stores, wholesale drug houses, wholesale grocery
houses, retail places, those were the main ones we covered.


Mrs. Whitaker:
What was your reception in those places?


Mr. Cromartie:
Ninety-nine times out of a hundred they'd want to cooperate
once it was explained to them.   Of course, a lot of them
when you got in, no inspector had ever been there before.
I don't think I had but one time, and this was a so and
so in Pensacola, Florida, a seedstore.


Mrs. Whitaker:
What year was this?


Mr. Cromartie:
I think it was the first year I was down there.    Nobody
had been there before and he was anti-Roosevelt.    I told
him what I wanted and he started raising hell about the
administration.    I said you can vote like you want to and
I'm going to do the same thing, but I have a job to do
and I'm going to do it whether you let me or not, whether
                                                               46

you want me to or not.     Well, he cooled off without any
problem.   You wouldn't run into that once in a year.


Mrs • Whitaker :
Did you buy these samples?


Mr. Cromartie:
Yes, you'd pay for them.     But here's the problem there.
When you got a sample, you had to get a copy of the invoice,
a copy of the freight bill--you had to show it was inter­
state shipment--then you got a dealer's statement where
a man signed that this material that you sampled came from
that shipment.     You had to be sure it was because he could
come up later and say "I was mistaken.n     That sample didn't
come from that shipment.     If you had a prosecution, that
was it.    They would never do that because it was always
explained to them why you needed that dealer's statement
just to complete our records.     But down South you didn't
have any problem like you did in New York, for instance,
or some of those other places.     The people down here were
more cooperative than they were any place I ever worked.
In Los Angeles, you hit a lot of the shyster manufacturers
and some of them just don't want to cooperate anyway but
in the Southern states you didn't have any problem.        I
didn't have any in Boston and that area.     I know around
New York and that area and Chicago we hadit all the time.
You had a different type of manufacturer really.     You
                                                            47

would go in a place of business and you might spend three
or four days.    There was a manufacturer in Plant City.
I'd spend four or five days there where you'd get all
these samples.    Then it would take the girl maybe an hour
or two to dig up the records and then by the time you
copied them and got the dealer's statements, you'd taken
up a lot of their time.     I can see how they could have
gotten irritated but they just didn't.     But when the manu­
facturers would come into Washington they weren't antagonistic
at all.   They wanted to get things straight if they could
without going to court.     They were the ones that were
actually behind the eight ball.     They were the ones that
had to justify their action.     They didn't really have any
reason to get irritated.     Of course, they hated all that
trouble and all but they knew they were wrong.     At least
we figured they were.     They knew that they had an opportunity
to fight in court but you don't fight those things in court
if you can help it.     Your expenses, your time, and all that.
The large manufacturers would send their attorneys in--
they wouldn't fool with it--they'd have an attorney either
in Washington that handled it or the attorney in their
home office would do it or they would come in themselves.
They had attorneys in Washington, that was all they did
was handle Food and Drug cases, insecticide cases.     Of
course they knew what the story was.     All they could do
was to stick to facts.
                                                              48

 Mrs. Whitaker:
 Did you deal to any extent of time with the manufacturers'
 associations, insecticide, disinfectant manufacturers?


 Mr. Cromartie:
 Oh, yes, all the time.


Mrs. Whitaker:
What were your relations with them?


Mr. Cromartie:
Very good.    I can't remember the names now.     They were
always there.      They would send their representatives in
on conferences, the Insecticide and Disinfectant Manu­
facturers Association and then the Agricultural Manufac­
turers Association • • • I've forgotten.


Mrs. Whitaker:
Mr. Hitchener, I believe.


Mr. Cromartie:
Mr. Hitchener was there.     Is he still there?


Mrs • Whitaker :

He was until just recently.


Mr. Cromartie :
Joe Noone was Hitchener's assistant.     He was a very good
                                                             49

friend of Dr. Reed.    Hitchener was the one who sat in on
all these meetings when they were working on the act.
Hitchener represented the agricultural end of it.      Dr.
Hamilton would represent the disinfectant manufacturers.
That was when they were going down the act paragraph by
paragraph.     I don't know how many conferences we sat in.
That was when I first went to Washington, when there were
only three of us there really.


Mrs. Whitaker:
That would be yourself and . . .


Mr. Cromartie:
Dr. Griffin and Dr. Reed.      Dr. Griffin was the one who
handled the technical end of it.      Dr. Reed didn't know
it; I didn't know it except what I'd gathered in twenty
years working in the field.      Dr. Griffin wrote the Act
and he handled all the problems that came up in these
conferences.     Of course, Agriculture would have a repre­
sentative there, ARS, or whoever was handling it then.
PMA at one time and then AMA and then AMS and then ARS,
I don.,t remember the order.     I think it was PMA, Production
and Marketing, that's what it was when I first went to
Washington, no, when I first transferred over.      Then
it went to AMA, then AMS, then they took it out of that
and put it under ARS, and now it's under EPA.
                                                                50

Mrs. Whitaker:
Was Hitchener particularly demanding?


Mr. Cromartie:
Very, very reasonable, and so was the disinfectant group.
They cooperated all the way and the fact is, I don't think
the Act would ever have been passed without the support
of the two groups.   They could have fought it.     They
realized that the Insecticide Act of 1910 was obsolete
and they could see that these new products were coming
in and something had to be done.    There wasn't any way
to cover them.    They were interested in the legitimate
manufacturers.    That's all they wanted to protect.       Of
course, they had their own members.     They wanted products
that complied with the law on the market the same as we
did.   As far as I know, there never was any rub.      Even
up to the end, the Division had the full cooperation
of both groups.


Mrs. Whitaker:
About DDT now, when it first came in


Mr. Cromartie:
The way I remember it, DDT first came on the market in
this country in 1945.    At that time Geigy had the American
patent and theoretically everybody had to clear it with
them before they could put it on the market.      But DDT
                                                               51

was so easy to make that anybody could make it.        I don't
think Geigy ever exercised the patent on it.        There was
DDT all over the country.    At that time people were coming
in the office--and there was only a small force at that
time, Dr. Griffin, Dr. Reed, and myself--and we didn't know
too much about DDT.     All we knew was that it was used in
Italy for lice on humans.     When it came over here as an
insecticide, they would come in the office with solutions.
All you had to do was mix kerosene and DDT.     Kerosene
would dissolve about five per cent DDT, that was as far
as it would take without another solvent, I mean, like
benzene and that type, the petroleum derivatives.        They
were selling it for anywhere from $1.50 a quart.        They
wanted the labels corrected at that time before they
put it on the market.     So everybody and his brother that
could get hold of DDT was coming in to get the labels
commented on so they could put it on the market.        You
could have taken $5,000 worth of DDT at that time and
retired, the price was high compared to what it is now.
The main thing they used it for then that I know of was
for household, mainly roaches, that type of thing.        They
were going to town on it.     Things were hectic.


Mrs. Whitaker:
That was even before the '47 Act.     All that you needed
to do at that time was to check the labels.
                                                             52

Mr. Cromartie:
Yes, check the labels. Tell them that we didn't have any
objections on it and they could use it.       At that time
I don't think they even had to have an adequate precautionary
statement.     It was just a household spray, to spray on the
rugs or floors or whatever it was.       They didn't know any­
thing about DDT.      They didn't know too much about the
toxicity of it, for that matter.       They didn't know that
residues remained over an indefinite period of time.
They were pretty liberal.       Of course, nobody knew how
far you could use it.      From an enforcement angle, we had
to be fairly careful.      At that time, when it broke in
this country, I don't think there were any agricultural
uses for it.       I think it was strictly household or human.
Of' course, after that they just went rampant on DDT, that
was everything.       It was good for what ailed you.


Mrs • Whitaker :
It replaced the arsenicals?


Mr. Cromartie:
To be frank with you, I never got as hot and bothered
about DDT as a lot of other people have.       In my opinion,
and mine isn't scientific either, some of these other
chlorinated hydrocarbons are worse than DDT.       They just
don't dissipate and that's the whole thing.
                                                              53

Mrs. Whitaker:
Was there any conflict between the Insecticide Division
of Agriculture and Food and Drug over the use of DDT?


Mr. Cromartie:
Not at first.    They didn't know too much about it.      I
still don't know what the tolerance is on DDT.      It's not
used now on food crops.     To me it's still a good insecticide
if you can keep it where it won't run into the creeks or
rivers.    After DDT came out and some of the other new
chemicals, every time you had a fish poisoning or any-
thing else they blamed it on DDT.     We were always investi­
gating these outbreaks.     They'd have a fish poisoning down
in the Mississippi River.     DDT running off.   Well, they'd
find out it was something else.     It was all over the
country.    We were always checking on these reports.         Half
the time it was something to do with nature or something
else.


Mrs. Whitaker:
Before 1947 you couldn't have taken any action against
DDT anyway, could you?


Mr. Cromartie:
Just on the misbranding or adulteration.     DDT was the
first one and then they just kept coming out •..••••
                                                                     54

Mrs. Whitaker:
In the late   1   30 1 s and early   1   40 1 s:, during the time that
the fruit growers were so concerned about the spray residue:,
the arsenicals, there were a number of substances--rotenone
was one of them--tried out as a substitute for arsenic.
Was DDT viewed as sort of a.


Mr. Cromartie:
Not at that time.


Mrs. Whitaker:
I mean in the      1   40 1 s when DDT was introduced.      Did agri­
culturists look to that as the salvation from the arsenical
problem?


Mr. Cromartie:
Yes.   A cure-all.         And it was pretty good.


Mrs. Whitaker:
It did accomplish what they set out to do?


Mr. Cromartie:
It is about as good all-around as you can get.                I don't
think you can use chlordane on agricultural crops.                You
can't use DDT now.          They had DDT for everything:        household,
agricultural.          The fact is, you can't use it now.         I've
got a yard spray out there now--I don't Ir:..now how long
I've had it--part of it is DDT.              I only use it on the
                                                                  55

yard.      I don't think you can buy it anymore.      I think they've
taken it off the market.        Now they recommend chlordane
for non-agricultural uses which is just as good.          I think
the residues build up in that.        I don't see much difference.
I don't know, I'm no scientist, it's just from the practical
end of it.


Mrs. Whitaker:
Then after the 1947 Act you did have registration and the
bulk of the products that you were registering involved

DDT, I suppose?


Mr. Cromartie:
 No, they had a lot more of them at that time.         From   1
                                                                  45
 to   1   47 they started coming out with new ones.     The advantage
 of the 1947 Act was that they had to have proper precautionary
 labeling.       They also had to establish the effectiveness.
 They couldn't just say this is good; they had to show
 that       it was effective.   They had to have data to show
 that.       Of course that ran into millions for these big
 manufacturers.       They could spend millions on research
 to develop new products that were effective.          After DDT,
 DDD came out and then they just kept branching off, ma'.king
 new products.       I don't know how many.   They'd change one
 of the chlorine groups and they'd have a new product.


  Mrs. Whitaker:
  Before the 1947 Act you had to prove in each case whether
                                                           56

or not the product was effective or not.


Mr. Cromartie:
Yes, we had to show it.    They'd put it on the market and
we'd have to pick it up.


Mrs • Whitaker:
And then after registration the product had to be shown
effective first.    Then.'if you picked up a product under
the 1947 Act and it did not comply with the registration
specifications you would have an automatic case against
them?


Mr. Cromartie:
That's right.     If they used a label that was different
from what they had registered, even if the composition
was different, there would be a violation to the effect
that the labeling differed in composition to that accepted
in the registration.     If they changed directions, the
directions were different.     So there were two clear-cut
cases.   Once they registered a label, they had to use
that number and they had to use the same label that was
registered.     Now, of course, there were times when we
would find out later that we had accepted a label that
later had to be changed.     It wasn't anything serious.
We might find out it wasn't effective for this one thing
and then we would contact the manufacturer or registrant
and they would bring it into compliance.     Not only that,
                                                             57

if we found out something wasn't effective or the precau­
tionary statement wasn't correct, we'd just cancel the
registration.      They had to start over.


Mrs. Whitaker:
The cost then of registering a product would have fairly
well removed the small businessman from the insecticide
or disinfectant business?


Mr. Cromartie t:
Not on registration, for the simple reason that if he was
buying raw materials--I mean by raw materials products
that he could take into a small plant and formulate--
the manufacturer would furnish him with labeling.      He
might say it was adequate.      In other words, the manufacturer
had already registered.      So if he was buying DDT, say,
from a manufacturer and he wanted to make a simple house­
hold spray, the manufacturer could give him a distributor's
label that would comply.      In other words, he could use
the manufacturer's label which the latter had registered
with a qualification.      A lot of them did, disinfectant
manufacturers and agricultural, too, for that matter.
They could register one product.      I know of one case
that they had over five'hundred distributor's labels.
In other words, you took his label and took a stamp or
printed your name on the bottom, "distributed by."      All
the manufacturer did was register their label and as they
found a new customer they would send in his name as a
distributor and so the distributor was in compliance with
the law.   He used the same number, the same registration
number.    In other words a manufacturer could sell his
product under numerous distributor's labels.     Disinfectants
were one of the types on which there were hundreds of
distributors' labels.


Mrs. Whitaker:
For the same product?


Mr. Cromartie:
The same product.


Mrs. Whitaker:
Disinfectants remained a fairly substantial part of your
enforcement work, then, after 1947.


Mr. Cromartie:
Very much so.    I tell you why.   They became such a value
in hospitals, the sanitation end of it.      various institu­
tions,jails, any public housing.     Back in the old days,
you could go by a county jail and you could tell what
they used for a disinfectant.      It was a coal-tar disin­
fectant.    You could smell it two blocks.    They wanted
something that didn't have that obnoxious odor.      They
developed these disinfectants that were effective without
giving off telling odor.    Your bathroom deodorants are
                                                            59

aerosol sprays without the disinfectant qualities.        Some
of them have both characteristics.     What's this well known
one that used to be a coal-tar?     It is used a lot in house­
holds.   It used to be coal-tar and they've got it now where
it's deodorized.   They sell millions of it every year.
I don't remember these names, it's been so long.     We
spent a lot of time at hospitals.     About the best thing
that a hospital could have would be a good housekeeper,
as far as the sanitation was concerned.     The jails and
nursing homes and hospitals use many disinfectants.


Mrs. Whitaker:
You would pick up these samples?


Mr. Cromartie:
All the time.    That's some of the points that we concen­
trated on for the reason that they would buy in quantities.
The way we did in the war, the way some of these supply
depots bought was funny.    I covered one place, it was
down in Alabama, they had 50 55-gallon drums of fly spray
that they wouldn't use up in years.     Not only that, for
mosquito control these army camps would buy disinfectants
from the disinfectant manufacturers and i t wasn't anything
but crank. case oil with coal-tar disinfectant in it.
Then the anny camps finally got smart and with all these
trucks and jeeps they had, they would use the drained
crank case oil for mosquito control.     If you get a heavy
                                                           60

rain down in Mississippi or Louisiana, you get water col­
lecting and pretty soon you got mosquitoes and half the
camps were in mosquito prone areas.    They were paying
$1.50 or more a gallon for crank case oil for mosquito
control.


Mrs. Whitaker:
Did you have a cooperative arrangement with the Public
Health Services as far as your enforcement work    ...
Mr. Cromartie:
As far as I remember, we never worked with Public Health
at all.    The fact is, I don't know how they operate.


Mrs . Whitaker :
I don't either, for that matter.


Mr. Cromartie :
These supply depots, I don't know what they are, what the
name of it. is, but GSA I guess would be one good example.
They would buy in quantities for the different agencies
but we would only sample when they would ask us or when
they had received something by checking and found it hadn't
been registered.    At first, they weren't too particular
about registration.    They did get to be later on.   They'd
call up if they were in doubt about anything.     I know
there in Washington, when I was there by myself as chief
                                                                61

inspector, they would call up about products and then I
would go down and sample it.         There wasn't anybody else
in Washington to do it.


Mrs • Whitaker :
Some of them bought on their own specifications?


Mr. Cromartie:
That's right.      They had their own specifications.     GSA
had it.


Mrs • Whitaker :
So actually a product that would go to GSA, for instance,
under GSA specifications •     . .

Mr. Cromartie:
We wouldn't do anything about it unless we had a special
request.


Mrs. Whitaker:
Those products were generally not labeled in any way
other than with GSA specifications?


Mr. Cromartie:
No.   They would be labeled with the manufacturer's regular
label but they'd have their own specifications just like
Sears Roebuck and Montgomery Ward.        They have their own
                                                           62

laboratories and they would check their products.    The
manufacturer selling to Sears Roebuck, either Sears Roebuck
or the manufacturer had to have that label registered.
They would check disinfectants, they would check everything.
They had good laboratories.


Mrs. Whitaker:
To check specifications?


Mr. Cromartie:
Yes.


Mrs. Whitaker:
What was the attitude within the Insecticide Division
concerning the 1954 Miller Amendment where the tolerances
were tied back in with your Act?


Mr. Cromartie:
There wasn't too much we could do about it.     That affected
mainly Food and Drug.   At one time, I've never been certain,
Food and Drug, right after the residue problem broke, would
have liked to have taken the Insecticide Division back,
when they saw that it overlapped so much.     Food and Drug
said they didn't.   That was the last question that was
asked me on this investigating committee when Dr. Hays was
there.   I wa.s the last one they called in enforcement
and .•••••••••••• Lemon, I think he's commissioner of
agriculture in California now, anyway he used to be state
Food, Drug, and Insecticide, he asked me if I thought that
the Food and Drug Administration could enforce the Insecticide
Act better than the Insecticide Division could.    You know
the answer to that.    I wasn't going to say yes even if I
believed it but I didn't think they could do it as good
for the simple reason that I spent about ten years with
them on the enforcement act and I knew how they enforced
them then.   It would have to have been different when all
these other new products came out.    Food and Drug was just
too big really to take on any more.    They have more than
they can handle now.    The 1947 Insecticide Act turned out
to be a bigger job than a lot of them figured when it was
passed.   I still don't believe that Food and Drug could have
done it better.   I didn't have any prejudice against Food
and Drug at all because my ten years or eleven or whatever
it was were very pleasant.    The only reason I transferred
was because I wanted to get back South.


Mrs. Whitaker:
From the correspondence in the National Archives and other
sources I do have a feeling that there was a little tension
between the Insecticide Division in the Department of Agri­
culture and Food and Drug that perhaps Food and Drug might
have felt, especially concerning tolerances, that Insecticide
was not doing all it could do.    Did any of this come down
to the actual working level where you felt any of it?
                                                            64

Mr. Cromartie:
It wouldn't have come down to the enforcement end of it.
It would have been mainly with the scientific section.
I never did get into that residue angle.    Of course, Food
and Drug would get out in left field at times.    You re­
member the cranberry deal.    That's a good example where
they were entirely wrong and the taxpayers wound up paying
the growers for the damage.     It wasn't the Insecticide
Division at all.    One of the state agencies, or county
agencies, had just used the stuff and it wasn't even
registered for that use.     They'd get out in left field
now and then.    I'd see it all the time.   They'd find a
few cases of something.    What was this potato soup that
they had all this trouble about?     They broke the firm
and they only had one batch or two.     Of course, I can
see their viewpoint too, that they can't afford to take
a chance.   We've seen two or three reports in the papers
here the last five or six months with tuna coming in.
They'll find one, there might be one batch, that is bad.
Of cour$e, if it's botulinus or something like that,
they've got to stop it right quick.


Mrs. Whitaker:
Their work is more immediate than the Insecticide Division.
Perhaps you had a little more leeway in products that
you were dealing with?
Mr. Cromartie:
The thing or it is that when they'd register a product,
when they'd set up tolerances, the manufacturer had to
furnish data to show that the uses wouldn't exceed those
tolerances.    At the end we were sending labels to Food
and Drug to pass on and one or two other agencies..    Well,
it slowed things up so.     A lot of these things Food and
Drug didn't know the answers to.     Towards the end there-­
and I don't know what they're doing now--when a residue
was involved then the label was sent over to Food and Drug
for them to review.     And there was one or two other agencies,
I think it was entomology maybe, maybe it was just Food
and Drug.     At one time all our labels where a residue was
involved Food and Drug had the final sayso on.     They could
refuse registration on it.     These overlappings didn't work
out too well for expediting registration.


Mrs. Whitaker:
Did the manufacturers generally • • •


Mr. Cromartie:
Oh, they were raising hell all the time about holding up
the labels, five or six weeks, or two or three months.
We finally set a deadline on it, that they had to be
back within a reasonable length of time.


Mrs. Whitaker:
This was just an informal arrangement between you and
                                                            66

Food and Drug.


Mr. Cromartie:
An informal arrangement with Agriculture that pressure
brought on.   The two Secretaries had to get together on
this.


Mrs. Whitaker:
After 19sq., after the Miller Amendment, do you think that
the pressures you were subjected to from manufacturers
increased considerably from what they had been before?


Mr. Cromartie:
I wasn't concerned with that.     You might say mine was
off in a different section.     I do know that the manufac­
turers wanted to get a product registered.     In other words,
you send a label in, say, November, you want to get that
product on the market for the spring, particularly if it
is an agricultural insecticide.     If that label was held
up two or three months, they would miss a whole season.
So they probably put pressure on to get the labels handled.
We had pressure all right because we didn't handle them
quicker but we couldn't handle them quicker.     Finally,
a deadline was set on them.     At the time we either had to
tell them yes or no.


Mrs. Whitaker:
Were the enforcement problems compounded after 1954?
                                                           67

Mr. Cromartie:
It didn' t make any difference to us.   When~_it came to us,
the labels were finished.    The products either had to
comply or not so we weren't in all those hassles.    The
rough work was done before they ever got to us.


Mrs. Whitaker:
You simply picked up samples?


Mr. Cromartie:
After it was through and after it was processed, then
we took them from there.    We didn't have any of those
problems, thank goodness.    There were a lot of problems
from '50 to '65.


Mrs • Whitaker :
Did the Department of Agriculture, or the Insecticide
Division rather, have its own laboratories or were you
using the general laboratories that ARS furnished2


Mr. Cromartie:
We had our own labs.


Mrs. Whitaker:
In the South Building?


Mr. Cromartie:
No, they were out at Beltsville.    We had testing stations
                                                           68

at Beltsville for fungicides and insecticides, then we
had the rodenticide laboratory and chemical laboratory.
They would actually do field testing.     So if they had
a fungicide they wanted to test, that they had registered
and they wanted to be sure it was effective, we'd go
ahead and test it in the field, you know, on actual plants.
And, of course, on all your household insecticides when
they weren't certain of these, they'd test them against
roaches, fleas, lice, either on animals or on plants or
on the areas, one of the three.    We had a pharmacology
lab, a bacteriological lab, and a chemical lab and the
testing stations out at Beltsville.     We had a chemical
lab in New York.   All they did was to analyze the samples
and report whether they were deficient or not.     They'd
go to Washington and they would be reviewed.     They went
through each section.   The Chemistry section would handle
them first, then if they were a disinfectant or germicides
for inanimate objects, they'd go to the bacteriological
lab.   If it had entomological claims, the entomological
section would handle.it.    The fungicides, the plant pathology
section would handle it.   For precautionary statements,
pharmacology would handle it.     Each one of them would
handle it before it got to enforcement.     If chemistry
found that it was deficient, they would make a report
to that effect.    If bacteriology found it ineffective,
they would make their report.     The rest of them would do
the same thing.    Then when it got to us in the enforcement
end, we would have to consolidate those charges or violations.
                                                          69

If there were no violations, the cases were placed in
permanent abeyance in which no action was indicated.
That's what the section would say if it was all right.
Then it would go on to the next section.      It went through
the rounds that way before it ever got to enforcement.


Mrs. Whitaker:
Somewhere in my reading I have encountered suggestions
for registration on the federal level as far back, I believe,
as the 1920 1 s.   When do you recall the question of regis­
tration first arising on the federal level?       I wondered
if it was before Dr. Griffin's draft.


Mr. Cromartie:
It was in their minds for years because that was one of
the main things that they wanted to incorporate into the
new act.      It was easier to make the corrections before
it got on the market because we knew that you couldn't
cover all of them.     All we were doing was spot checking.
When we started out on registration, Dr. Reed asked us
to give an estimate of the number of products that we
thought we would register.      I came up, I believe, with
the answer 55,000.      Before we got through it was probably
150,000.      I don't even know what it is now.   The number
of products on the market then was tremendous, even in
1   47 and 1 48.
                                                           70

Mrs. Whitaker:
There would have been no way for seven inspectors to . . .


Mr. Cromartie:
No, a hundred couldn't do it.


Mrs. Whitaker:
And it was never significant enough to the Department to
increase your appropriations to any extent at all during
the years prior to 1947?


Mr. Cromartie:
They were fighting for appropriations even up to the time
I left.   We increased the inspection force as much as we
could.    They increased the reviewing sections, they increased
the laboratories.    But the products were coming on the
market faster than you could handle them, that's the whole
thing.


Mrs. Whitaker:
From your experience with all of the different Secretaries
who handled the department, and you in a peripheral way,
from whom did you get the most cooperation?    Did any
one of them express more concern with insecticides perhaps
than the other ones?


Mr. Cromartie:
The Secretaries the last 12 or 15 years were the most
                                                                71

interested because pesticides had become more involved
and the public was more concerned.


Mrs. Whitaker:
What were some of your experiences with fanners and other
consumers?


Mr. Cromartie:
The users on these fa:nns weren 1 t too well educated.      The
owners and all probably don't know any more about it than
they do.      They just buy what the salesman tells them is
good for it.      What I was actually doing was sampling some
seed treatment material, I think it was in Fort Valley,
Georgia, down in your neighborhood, and I was talking
to this Negro there and he was practically crippled and
I asked him what the trouble was.       He said he thought
he had been poisoned dusting cotton seed.          Those seed
treatment materials for that type at that time were all
mercury preparations.


Mrs. Whitaker:
What year was this?


Mr. Cromartie:
It was   1   41 or '42, somewhere back in there.     I didn't say
anything.       I knew his time was limited.   He never would
get old.       They were using this drum duster--you know it
was a cotton gin, they sold cotton seed and fertilizer
                                                               72

to the farmers.        They would buy the seed and then they'd
treat them.     They were using a drum, a 55 gallon drum with
an electric motor, like I was telling you, for simple mixing.
All this dust was coming back through there and he was
breathing it.     He   would probably die an invalid but there
was nothing to be done for him at that time, not on mercury.
And parathion, people were careless with the use of it, as
toxic as that is.        I remember here in Tampa, whoever used
the parathion threw the bags out and these kids, I think
they were colored children, took the bags--you know these
old time swings you'd put on a limb with a rope and a
board.   Well, the board got a little hard, I guess, and
they covered the seat with parathion bags and it killed
about three of them.        There wasn't a thing in the world
you could do.     We had cases in Louisiana where these house
to house salesmen were selling parathi-on for roach killers
in the homes.     Well, it's effective all right in more
ways than one.     It was just plain ignorance.     A lot of
them didn't know how to use it and didn 1 t care if it
was effective.     Getting back to the Secretaries of Agri­
culture, I don't think any of them were interested or
familiar with the Act until they started having these
fish kills, these drifts of weed~~killers.       Spray them
on one field, they 1 d drift over and they'd clean out
the crop on the other.        They got so much publicity on
that that they just had to do something.        These weed
killers are dynamite when they aren't used right.
                                                             73

Mrs. Whitaker:
And the weed killers were not covered under the old act.


Mr. Cromartie:
Under the 1910 Act, they weren't.    Tomatoes and cotton are
particularly sensitive to some types.    Weed killers, when
they drift, will defoliate them.    Those are things that
they use for testing for drift; they use tomato plants.
But I guess they've got those pretty we~l under control.
They had so many law suits that the insurance companies
would make them if nothing else.


Mrs. Whitaker:
We were talking a few minutes ago about the careless
use of these materials.    This brings up the question
of use and application which is one of the critiGisms di­
rected against the 1947 Act, that it did not take into
consideration the fact that a product might be recommended
for a particular use but there was no way to insure that
the consumer would actually use it under those conditions.
Did discussion on controlling the use and application
of insecticides come about while you were still in the
Department?


Mr. Cromartie:
No.   You can 1 t legislate against ignorance.   There 1 s
nothing in the world you can do.    You can put it on
the label.    Everybody now says read the label but a
                                                            74

lot of them still don't read the label.       If they follow
the labels on practically all the products now, they 1 re
safe.    When you tell a kid don't stick your finger on that
hot stove, he may be curious and do it anyway.


Mrs. Whitaker:
And you think that by licensing operators or users of
insecticides, or pesticides as they are referred to now,
might eliminate this under the new law?


Mr. Cromartie:
On the new Act, do they license operators?


Mrs. Whitaker:
Yes.    It is my understanding that certain products • • •


Mr. Cromartie:
I've got the new Act but I've never read it.       I know they
were talking about it for years.


Mrs. Whitaker:
This is what I wanted to get.     Who introduced the idea,
this concept of use and application~     Do   you recall when
you first heard talk about that?


Mr. Cromartie:
No.     A lot of the states licensed them but the federal
government didn't.     They should have made them obtain
                                                           75

licenses because these pest control operators .•.•..•. I
know the yard people here can 1 t even use insecticides
without being licensed.     They'll put out fertilizer but
they can•t put out insecticides because they have to have
a license.    Some states have had that for quite a while.
I   didn't know the federal government had it.   I know

they had been talking about it.     The operators were exempt
under the '47 Act.


Mrs. Whitaker:
At the time that Dr. Griffin was writing the 1947 Act,
was there any suggestion that use and application be
included?


Mr. Cromartie:
I don't remember for sure but there undoubtedly was because
the fact that they were exempt came up.     I imagine at that
time everyone felt there was just a limit to what you could
enforce.     What the new act covered was more than could
be enforced, you know, with the personnel they had.


Mrs. Whitaker:
And the appropriations that you were getting.


Mr. Cromartie:
Not only that.     I imagine they felt too that if .some of
the responsibility reverted back to the states, they would
                                                           76

have to do that.    For years, some of the states didn't
even have an insecticide act.    Even when I left, some
of them didn't cover disinfectants.    They came under the
old act for the simple reason they were fungicides.       That's
the way they incorporated them, the fact it was a fungicide.
The old act didn't even cover disinfectants, I mean, as
that.


Mrs. Whitaker:
I remember in my research I encountered the argument that
Dr. Haywood was not in favor of having disinfectants classi­
fied as fungicides in 1912.     By 1914 he had changed his
mind and then, of course, the campaign against disinfectants
became very active.    What was your feeling on that?     Do

you think that disinfectants belong under the insecticide
act?


Mr. Cromartie:
Definitely.   I think it could be classified as a fungicide.
And then you could stretch it on.     You know how they inter­
pret some of these laws now.     The way they interpreted
them then was very conservative to what they do now.
It held up in court so that's all you need.     Most people
think of a fungicide as an agricultural product but athlete's
foot is a fungus.     When they start recommending athlete's
foot preparations for use on your socks and dusting in your
shoes, then it becomes subject to the Federal Insecticide,
                                                          77

Fungicide Act.    As long as they confine it to your feet,
then it's Food and Drug.    As long as they can get an
inanimate object in there they bring it under the Insecti­
cide Act.


Mrs. Whitaker:
I noticed in the 1930 1 s especially, about 1935 or 1936,
the Insecticide Division of Food and Drug as well as
Food and Drug itself were bringing suits against the
same products.    I wonder if you have any recollection
about that, whether there was a particular campaign on
at that time that required both acts to get some unde­
sirable product off the market, for instance.


Mr. Cromartie:
I don't remember any particular cases but it could very
easily have been on many products.     The treatment of
athlete's foot would have been_,one.    If that was ineffective
on your feet and socks and shoes, both acts would cover
it so they'd cover it under both acts.     Quite a few products
overlapped, even some of the stock remedies would overlap.
Even germicides could overlap, for that matter.     In other
words, if you had a germicide that you were spraying on
your desk or your telephone mouthpiece, it's subject to
the other act if recommended for human use.     If they say
spray it on for sunburn, then you got the two acts in it.
I imagine there must be many many products that are on
the market now.
                                                          78

Mrs. Whitaker:
That would come under both acts?   I thought perhaps if
the courts did not uphold the one case against an unde­
sirable product, perhaps another judge or another jury
in some other district might.   I wondered if you might
recall the philosophy of the thinking behind that.


Mr. Cromartie:
Well, I imagine if one district did turn it down on a
situation like that, unless it was way off base, I imagine
the other district judge would use it as a precedent and
turn the same thing down.   Of course, there could be
technicalities.   Another judge might have found them
guilty without any question and the second judge would
have found them guilty just on the precedent.     This pre­
cedent thing is a big factor in these enforcement cases.


Mrs. Whitaker:
Did you find that it worked to the detriment of enforcement?


Mr. Cromartie:
I would say no.   It would be kind of hard to say on it.
In many cases an enforcement agency wants to get a pre­
cedent.   They will go to court on a case that they know
they may lose but they want to get a precedent.    So they'll
go to court on it and if they lose it, it's out then so
they're through with it.    If they win, then they'll start
                                                            79

branching out.


Mrs. Whitaker:
During the time :that you had enforcement under your con­
trol, if there was a product that you felt should not
have been on the market, but you thought perhaps you
could not get a court decision favorable to you, would
you withhold bringing suit on the basis that if you could
not get a conviction against the company it was almost
a license then for the company to continue operations?


Mr. Cromartie:
If you can't get it off the market, it is.    Getting back
to lindane vaporizers, we were never able to prove that
they were dangerous to human use.   We had cases where
they had, but they were such examples, I mean they wouldn't
have enough weight in_;court for you to outlaw them.   So
we would have to stick to either non-registration or
ineffectiveness.   I guess they're off the market now
because we kept getting behind them so.    I haven't seen
a lindane vaporizer in years.   When the fad got over,
there weren't but two or three manufacturers that put
them out.   It was a fad, more or less, I think.   Even
though they were effective, if you didn't stay in the room
and breath the vapors, that was all right.    I think the
fad wore off and then they got on these strips.    We had
letters complaining on those at times.    They'd use them,
                                                            80

say, in a trailer and the strips had adequate precautionary
labeling on them but we would have complaints about some­
body becoming ill.     We don't know whether that did it or
not but we had to follow up on them anyway.


Mrs • Whitaker:
Going back to the vaporizers, I remember reading about
that.   There really was quite a controversy about that.
I think the American Medical Association was involved in
it and Food and Drug.


Mr. Cromartie:
Everybody was.


Mrs. Whitaker:
Do you remember any particular cases where you had ta.ken
a product to court?


Mr. Cromartie:
No, we never did take one to court.      I don't remember one.
I know we didn't take o:reon toxicity.     I'm sure of that.
I know we worked on it.      I've forgotten it since you men­
tioned that.      We tried to get the support of some other
agency--it could have been Food and Drug, I won't say for
sure--but we couldn't get them to back us up.      So we had
to stick to ineffectiveness and back to registration again.
They couldn't register them unless under protest.      We
wouldn't register them for some reason or other.      We
                                                          81

wouldn't register them for the fact that they hadn't furnished
sufficient data to show they weren 1 t harmful.    If they would
ship them out anyway, they could sell them intrastate but
they couldn't ship them out of state.     That was the only
way we could control them.    That's what happened in this
Texas case where the courts wouldn't go through with the
seizure, it wasn't registered.     It was strictly in violation.
That was the .only way we could slow them up.     We never
registered it.   After so much publicity came out about the
danger of them, we'd register them under protest.      They
quit manufacturing them.


Mrs. Whitaker:
Did you have much problem with this registration under
protest?


Mr. Cromartie:
At the time I left, I don't think there were more than
one or two if that many.     I don't :eemember one lindane
vaporizer being registered under protest.     We had trouble
with it but they didn't follow through on it.


Mrs. Whitaker:
The manufacturer did not?


Mr. Cromartie:
The manufacturer would not because he knew if he followed
                                                           82

under protest, the penalty was a whole lot worse.    The
trouble was that they could register under protest and
it might take us five·_,years to show that it was dangerous.
We might not ever be able to show it.   Some of these things
take a long time to support in court; some of them you
never can really.


Mrs • Whitaker :
Do   you think that the courts in the last years of your
service with the Insecticide Division became more coopera-
tive with you?


Mr. Cromartie:
Yes.    They just became more familiar with it.   There was
so much publicity on it that they couldn't help but become
more familiar with it.    Not only that, they began to
recognize the importance of these types of products,
weed killers, insecticides, fungicides, those types of
products.    There was so much damage done and in 95 per
cent of it it was misuse.    If they had used it according
to the labels, there wouldn't have been any problems,
that's the whole thing.


Mrs. Whitaker:
You said you cannot legislate use without having regis­
tration of the operators.
                                                              83

Mr. Cromartie:
That's right.    You can't legislate against ignorance.
Never been able to yet.     There at the end we were spending
hours and hours where damage had been done either to
humans or crops or something strictly from misuse.        I
know we'd get a complaint on Friday on somebody killed,
say, in Missouri.    Well, I'd have to get on the phone
and call the inspector in that area and tell him to get
over there.     He could get over there on Saturday.    We
liked to get there as soon as we could.     He'd get over
there and he couldn't get any reports from the family
particularly.    What you'd wind up with, this fellow was
out spraying in the summertime in his shorts and he had
had several drinks and he wasn't using any care and the
spray got all over him and consequently killed him.           You
can't stop that.     I know I spent a week down in Mississippi,
or up in Mississippi from here.     A fellow had about sixty
cows killed.     I went over there and I couldn't get too
much information from the vet.     He gave me enough that
I could start operating on.     You see, the insurance com­
panies get involved in this.     There are claims.     And if
it's misuse or something like that, they aren't going
to pay a claim like that.     So what had happened was that
this fellow turned this Negro loose to spray the cattle
and he used cotton spray.     Well, you can imagine what
it did.   It killed the cattle right off.    There wasn't
anything we could do on it.     It was strictly misuse.
                                                           84

No federal violation was involved.     All we could do was
just write up a report on what we found and what had
happened.   Of course, it was a pretty expensive experience
for that grower.   He was a big grower.    I don't know
whether they ever collected on the insurance or not.


Mrs. Whitaker:'.
They were time-consuming on your part.


Mr. Cromartie:
We had to follow them up.     We'd have calls from the Secre­
tary's office and everybody else.     What had we dgne~on it.
All those reports took time.     And a lot of running around.


Mrs. Whitaker:
After the Rachel Carson book, Silent Spri;ng, came out in
1962--that was in the last years of your service there-­
what was the department's reaction to Miss Carson's pub­
lication?


Mr. Cromartie:
I don't know what the department thought.     I got an idea.
She was a marine biologist and didn't know too much about
insecticides in my opinion.     Of course it was spectacular
and that's what it took to sell the book.     She did bring
it to the attention of the public.     I'll hand that to
her, which was good.   I never thought too much of the
factual end of it on what she wrote.
                                                           85

Mrs. Whitaker:
Do you remember Albert Deutsch?     Does that name call up
any memories for you?     He was in New York, a journalist,
and he wrote the first series of really sensational articles
about DDT as a danger to human life.     Shortly after his
articles appeared in 1947, Food and Drug and the Depart­
ment of Agriculture issued a joint statement concerning
the use of DDT in dairy barns.     Have you any recollections
on that?


Mr. Cromartie:
I don't remember the name.     I remember the Food and Drug
started checking residues in milk.     They found a lot of
it.     Dairies all over the country were stopped from selling
milk until they cleaned out, and it was quite a job.
Wisconsin, up in there, we worked with them closely.
I know they had several dairies closed.        I've forgotten
the details on it.     I know we had volumes of literature
both pro and c·on where DDT wasn't as harmful as they made
out._   It was effective, I'll say that for it.      I'm still
not convinced that DDT is as dangerous as they make out.
As far as I know there's never been a case of death caused
by DDT.     Wheth~r they've got it now or not, I donft know.
There have been cases where DDT was involved but it was
petroleum distillate.     In other words, you can drink
kerosene.     You know that as well as I do.     There•ve been
dozens of cases of death from just drinking the kerosene
                                                                86

and turpentine.     But as far as I know, there's never been
one death that's ever been tied down to DDT in itself.
The theory, I guess, is that the residues build up.         I

guess the reason is I went through that period when it
first came on the market and they used so much of it
that I never could get excited about the use of it.
I would use it now if I could get it but I would know
what I was doing.     I'll use chlordane around the house
for roaches and down here you get them by the millions
but I won't spray it inside.     I'll take a paint brush
and go around the door sills and that way I'll know in
my mind it's perfectly safe.     I think they let them use
it that way, I'm not sure.     But I wouldn't spray it in a
room and stay around very long.     I wouldn't do that.
They hopped on fifteen or twenty of the others that were,
in my opinion, worse than DDT.     Of course, the residues
do build up.     It seems to me like I read an article some­
where where they found DDT in some fish that had been
frozen in the Arctic for 200 years.


Mrs. Whitaker:
Yes.     I have read similar articles.   In fact the most
recent one concerned traces of residue in some Egyptian
tomb that had recently been unearthed.


Mr. Cromartie:
I remember reading that but I've forgotten the details
on it.
Mrs. Whitaker:
Did you make any changes after all of the controversy
about DDT in milk as far as the registration,the recommen­
dations?


Mr. Cromartie:
Oh, yes.   They .'.cut 1 t out for dairy use and food crops
for cattle.   When Food and Drug started finding residues
in anything that they considered dangerous, of course we
would have to automatically cut out its use.      We'd cancel
registrations for those uses right away.


Mrs. Whitaker:
What was the manufacturer's response when you cancelled
the registration?


Mr. Cromartie:
He couldn't do anything about it for the simple reason
that he hadn't shown that the use of that product for
that purpose would not be dangerous.     He'd shown to the
best of his ability but they come along and find other
things.    Well, they're always finding things that cause
cancer in anything now, you know.     I guess if you ate
enough corn meal it would probably cause cancer.


Mrs. Whitaker:
After 1947, did the major manufacturers object to charges
                                                           88

brought against them for the same reasons that they would
have in the earlier years, that is, the use of a notice
of judgment for instance by a competitor?


Mr. Cromartie:
They couldn't object because there wasn't anything they
could do about it.   It was public information.    They knew
it was unethical and they wouldn't do it.     The larger
manufacturers didn't worry too much.     If you'll check the
notices of judgrnent, you'll find very few serious violations
against them because they would fire a plant manager.       If
he didn't have control, they fired many of them that way.
If you take a firm like Niagara, Standard Oil had them,
and two or three others, but take any of the large manu­
facturers, they we~en't going to tolerate many violations
for the simple reason that they are so set up that their
operation will give them a guaranteed profit with making
a legitimate product.   So they don't want the publicity
anyway so they just won't tolerate it.


Mrs. Whitaker:
Most of the violations that you did find in the later
years were from small operators?


Mr. Cromartie:
Either that or unintentional.   Now a lot of the small
ones were unintentional.   Where the small ones had prob­
lems was that they didn't have any control measures.
You see, these large manufacturers had their own labora­
tories.     Not only that, they would keep samples of every
batch for two or three years so if anything came up they
could go back to their check sample and find out whether
what we found was right.     If it was, then they had no
argument.     It could be poor mixing, you see, something
like that.    Another sample might have been bad but it
would never come up because they'd never have any occasion
to use their laboratory sample.     We had never sampled that
particular batch.     The larger manufacturers tried to have
good control.     They don't want violations.   It isn't worth
the trouble to them.     They're going to make a profit if
they sell it at the price they're asking and if it's made
according to the formulation, so they aren't worried.        But
the smaller outfit--you take a disinfectant manufacturer,
for instance--he can make a mistake unintentionally.
Small agricultural mixers--and there are a lot of them-­
that just do intrastate business.     If they're honest and
want to put out a good product, which they should for
the simple reason they want repeat orders, they can get
these formulations without any trouble.     It's just a
matter of weighing, that's all.     But some of them cut
corners or some of them will get too big an overrun,
say a 2,000 pound batch of insecticide dust.     They'll
mix it up for that, for 2,000 pounds, and if they get
a 200 pound overrun they know something is wrong some­
where, even if that's only 10 per cent.     But if we pict.ed
                                                             90

up a sample 10 per cent short, we'd take action against
them so they shouldn't get any overrun like that.     They
may get a few pounds.     Now if they get too much of an
underrun, then somebody's in trouble with the head office.
When they start with the reports, you're supposed to have
2,000 pounds there and you got 1,800, they're ten per cent
short on the sales right there.     They have to have it
pretty well under control.     I think 95 per cent of the
manufacturers are legitimate, maybe higher than that.
The way things are now they have to keep the good will
of the customers.     Say, we made a seizure with a wholesaler
on a particular product, they're going to hesitate on
buying anything from that man next time because it's a
lot of trouble to them.     They've had their merchandise
tied up.    They 1 ve got to get their money back from the
raanufacturer.    They may be out of that product for two
or three weeks.     Most of them want to put out a legitimate
product.


Mrs. Whitaker:
In the later years, then, you found less need for multiple
seizures?   For instance, if there were not as many grossly
violated products on the market.


Mr. Cromartie:
That's right.     You might make one seizure on a manufacturer
and you might nick up ten more samples.     Each one of those
                                                                91

samples might be all right.    If you picked up five more
of his samples which were bad, then you'd go ahead and
make five more seizures on it.    Whether they've cut out
multiple seizures in the Insecticide Division, I don't
know.    It 5eems to me like they have;why, I don't know.


Mrs. Whitaker:
But they were still making multiple seizures in       1   66 when
you left?


Mr. Cromartie:
We'd make up to 50 if there were that many violations.
Of course, there weren't that many.    It's just a figure
of speech.    They weren't in compliance and they were
either ineffective or adulterated or misbranded, or all
three.    You had to get it off the market.   It is       my   under­
standing that they have loosened up on seizures during
the last five years.


Mrs. Whitaker:
In the later period, in the 1950 1 s and 1960 1 s, anything
that you can think of that is significant that I have
not asked about, I would like for you simply to tell roe
about it.


Mr. Cromartie:
If you ask questions, I could answer them.     The reason
I can't think them up is because for the last five years
                                                               92

it was wiped out of my mind.     I was through with it and
that was it.     There wasn't any occasion to do it.      I even
had long distance calls for doing consultant work.         I
wasn't interested in it.     When I left I was through with
it.   What occasion would there be?      If    I was going into
outside work on insecticide after retiring, I would just
have stayed up there because I made more money and I was
building up retirement so what was the reason to do it
after I got out.


Mrs. Whitaker:
I think it was in 1954, perhaps, when Mr. Ira D. Cardiff-­
does that name ring a bell?--brought a case against Food
and Drug to stop factory inspections and got a court
decision that did stop factory inspections.         It didn't
affect your work?     You were not using factory inspections
anymore by 1954, were you?


Mr. Cromartie:
No.     To start with, we didn't have the personnel; we didn't
have the time; we didn't have the money.         In other words,
you could go in a plant and it would take all day long to
inspect it.    You could take two days, or two nights, or
one day and one night to write it up.         All you have there
is jl!llSt the way he's manufacturing.    He can give you all
these formulas he's got.     Now, how do you make nicotine
dust?     Well, 99 pounds of this and one pound of nicotine
                                                          93

sulphate or whatever type of formulation he wants.    That's
no good.   When he makes the next batch, he may cut it down
50 per cent and then what good does it do.   Now, on sani­
tation, food products and drugs, it is entirely different.
On insecticides, I did much of that under the Food and Drug
Act that I thought was a waste of time.


Mr.s • Whitaker:
That was under factory inspections.


Mr. Cromartie:
Yes.   Of course, they worked on the principle that   . .   .
well, there 1 s another principle, I guess • • . you had to
spend so much time on the insecticide act in order to
justify the allotment that they gave them to enforce it.
The Insecticide Act is mainly regulatory and other than
registration it's just a question of whether the products
comply with the registered label or whether it's up to
its composition.   It's just that simple.


Mrs. Whitaker:
Walter Campbell set up, I think, the factory inspection
at the time that he was still chief inspector.


Mr. Cromartie:
I don't know how that started.   Of course, 1927, I was
in four years later.   I know we did it up until the time
                                                            94

I left.   Even one of the original inspectors for the Insec­
ticide Division was in Boston at that time.     After they took
over he was appointed inspector for the Boston area but he
died soon after that and they never put another one up till
years later.     Years after I got in, we put one back up there.
Even at that time they were making factory inspections.
There weren 1 t too many to make up there.   It was mostly
disinfectants and that type.     There weren't too many agri­
cultural insecticides manufacturers in New England for
the reason that agriculture isn 1 t the main:crop there.
I never did see any except apples and that kind of stuff.


Mrs. Whitaker:
This may be outside of what you were concerned with in that
time but if you have any recollections on it, I 1 d be glad
to have them.     The matter of a phenol coefficient on a
label for a disinfectant was the subject of a great deal
of agitation during the 1920 1 s and again in the 1930 1 s.
After about 1936 I have seen nothing further on that.
Do you recall the circumstances, why the manufacturers
dropped their push for including the phenol coefficient
on the label?


Mr. Cromartie:
No, I didn't know that had ever been a problem.     They
didn't have to make a statement but if they made it it
had to be correct.     In other words, no matter what they
                                                          95

put on the label had to be true in its entirety.     So
if they said the phenol coefficient was 7 and it wasn't
7 it was just misbranding.    We've had cases, I'm sure
of that, we had charges where the phenol coefficient
wasn't what they claimed.     The product was effective
but the phenol coefficient wasn't.     I don't remember
that ever coming up in the '40 1 s or even before that.


Mrs. Whitaker:
The push for that must have dissipated about the time,
or before the time that you went to Washington.


Mr. Cromartie:
It would have.   It could have been something like this:
that the Insecticide Act--and I don't remember this-­
could have required them to put the phenol coefficient
on and they didn't want to.


Mrs. Whitaker:
No, it did not require that it be stated on the label but
a certain group of manufacturers was trying to get the
Act amended to require a phenol coefficient.     It was never
done and I wondered if you remembered the circumstances
on that.


Mr. Cromartie:
No, I don't remember that.
Mrs. Whitaker:
It probably was no longer a problem by the time you went
to Washington as the head of the inspection and enforcement
in 1945.    It had probably already worn itself out in the
course of time.


Mr. Cromartie:
I can 1 t see that it would have been much of a major problem.
The fact is that anything they put on their labels had
to be a true statement so they didn't have to put it on.
Something else though, that could have been a selling
point for the disinfectant manufacturer.    Something's
coming back to me now.    One manufacturer might put on the
same type ofdisinfectant the coefficient of 7-1/2, another
one might put 5.    Well, his competitor would take that
label and say our coefficient is 2~1/2 times more than
his.   You're getting a better product.    He wouldn't nec­
essarily have been getting a better product.     I can see
where something like that might come out in the sales
end but as far as use and effect was concerned, it's been
so long I've forgotten how the phenol coefficient works.
I'm no bacteriologist so I won't comment on that.     I had
it down at one time but it must not have been too important
because I don't remember ever running into it.    We had a
very good bacteriologist in Washington.     He died of a heart
attack.     He was capable, easy going, and well liked by
industry.

                                                                 {
                                                          97

Mrs. Whitaker:
What was his name?


Mr. Cromartie:
Stuart.    They gave him an honorary doctor's degree from
a Pennsylvania University and they don't give them out
unless you are worthy of it.     He was the head of the
department there.     He was really good.   The whole country
recognized him as an outstanding bacteriologist and he
was.     We never had any trouble on disinfectants but they
knew that he knew what he was talking about in what we
found.     They never questioned those findings.


Mrs. Whitaker:
After 1945 :when you did go to Washington and it was just
you, Dr. Reed, and Dr. Griffin, you must all have known
pretty well what was going on between the three sections?


Mr. Cromartie:
The way it operated was this:     Dr. Griffin would take care
of office calls and that kind of stuff and Dr. Reed would
be the one that signed the actions and I prepared all the
cases.     I had to go through Dr. Griffin and he'd review
them and Dr. Reed would sign them and they'd go out.


Mrs. Whitaker:
To the solicitor's office?
                                                            98

Mr. Cromartie:'
Yes.    Then it got so voluminous that each section would
sign them.    I would sign them all.   Then they would go
out that way.     At that time the volume of work we did
compared to what we had to do later is not even comparable,
for the reason that we didn't have as many cases, and we
didn't have as many inspectors.     The amount of work that
five inspectors could turn in that you'd have to process
and the amount that fifteen or twenty could turn in was
a different situation altogether.      You've got more seizures;
you've got more notices of violation; you have more pro­
secutions; you have more responsibility in directing
inspection work.     We had to keep them so they were covering
the right fields.     And then we got word we had more inves­
tigations to make and things to follow up on.      I think
back in '45 and what it was in '55 and it's not even funny.


Mrs. Whitaker:
You were not given a proportionate increase in appropriations
or in personnel?


Mr. Cromartie:
The more work you had, you had to do it yourself.      The
output doubled.     Of course there was a limit to that.
Things have changed a lot since that time.      It used to
be when I was an inspector, you didn't quit at 4:30 or
5:30.    After the war, eight hours was considered a day.
                                                              99

Mrs. Whitaker:
Whether the work was finished or not.


Mr. Cromartie:
They'd put it off till the next day.       Conditions were
so changed that they could do it.     The way it was in
the old days you worked during the day and wrote up reports
at night.     If you didn't get them written up at night,
you did it over the weekend.     I guess everybody thinks
they work harder than the ones that move up.


Mrs. Whitaker:
I'm sure you did have a tremendous work load.       The records
indicate that and especially when I review the amount of
appropriations that you had and the meager increases that
came through the years.


Mr. Cromartie:
Well, they were even fighting for appropriations when
I left.     I don't know what they were.    I think we did at
one time get over a million and that was big money.          You
start working on $250,000 a year or $300,000, that isn't
much even for a limited number of people.       You didn't do
any travel much.     All the travel had to go to the inspectors.
Of course, at that time I've traveled on $3.50 a day per
diem, then it would go up to $4.50, and then $5, and when
I left I think we were on $17 or $18.      Even at that you'd
                                                            100

lose money on these short trips.       I!d go for two or three
weeks and it would cost me $200 or $300.      Hotel bills
would be $16 a day and then the incidentals added up.
They're much more liberal now, I imagine.       I   don't know
what they get.


Mrs. Whitaker:
I   don't know either.   I   would welcome any further recol­
lections you have, anything that I have not covered.


Mr. Cromartie:
It's hard to add to it.       If you have certain questions
to ask.


Mrs. Whitaker:
Did you do much cooperative work with the states?


Mr. Cromartie:
We did a lot at the time that the 1947 Act went into
effect.    The new Act authorized the department to cooperate
with other federal and municipal agencies, I think is the
term they used.    Of course, that brought in the cities,
for that matter, and the states.       Pretty soon after the
Act went in they started contacting the various state
agencies that had insecticide acts and several of them
didn't have them at that time.       The main states that had
them were the agricultural states like California, Missi­
ssippi, Alabama, Louisiana, Georgia, and Kansas •. Wisconsin
                                                        101

(they were mainly dairy) but they were very cooperative.
There were three or four more.     It seems to me like we
had fourteen states on the cooperative program.    Well, the
way it started out was they would have the state enforcement
officials come in to Washington once a year on a conference
and there they would discuss registration policies, labeling
policies, and new things that would come up.     Some of the
states after the 1947 Act went into effect also passed
acts that required registration.     Quite a few of them
did.   By checking there they would give us the information
on their registrations and then we could double check.
If they had a product registered that we didn't and it
was shipped interstate, we knew right off that that was
in violation.   Most of the states worked on the basis that
if the federal government accepted the registration they
would accept it.   That's all they had to do was give them
their number and label.   Then on the enforcement end of
it at that time the Department was short on personnel
and funds so we set up a program where they could collect
samples and analyze them and we would take action on
what they found.   One problem there was that the state
inspectors weren't familiar with the federal procedures
in that they didn't have to have interstate records.
They would see a product on the shelf and that was it.
They didn't care where it came from.    We tried to work
out a program where they could collect samples for us
and send them in and we would analyze them on their col­
lection records.   We set up what was really a very informal
                                                        102

procedure where they could collect samples and we made
some seizures on samples they collected which were in
violation.   We would take action on their findings, mainly
chemical, that's all they had.    That took considerable
work because you had to describe the sampling procedure
to the state inspectors with which they weren 1 t familiar
because we went into it in much more detail than they did.
We had to furnish them the forms to obtain the information
that we used.    You can't send an inspector out that has
never had any experience in collecting a sample that was
subject to the federal law.    That ran into a lot of work
in trying to clarify that.    When the inspectors would get
into the areas where the state inspectors were cooperating
they would work with them and try to clarify the procedure
that we used.    It was very effective as far as it went
but there were limitations.    You couldn't expect a state
man to go out and collect a sample like a federal inspector
who had had years of training.


Mrs. Whitaker:
Would it have helped you particularly during the growing
seasons when certain seasonal kinds of poisons were on
the move--cotton poison, for instance?


Mr. Cromartie:
You could be more productive at that time than any other
for the reason that there were more products available.
                                                         103

Mrs. Whitaker:
Was this a problem for you when you were controlling
inspection, that is, that it was so seasonal?   Did you
have to collect samples at a particular time of the year?


Mr. Cromartie:
Well, you have to, really.   You take Florida, for instance.
They would start shipping economic poisons, insecticides,
fungicides etc. down in November and December that they
were going to use in January and February because the
crop is much earlier here.   We would try to cover these
products before they got out.   Of course, your season
right now is still running on some products.    Second
crops of tomatoes, they've been planted within the last
month or so, the last six weeks at least.    Pretty soon
your Florida crops are going to be over.    That's why you
move up to Georgia and South Carolina and the other Southern
states where the season might be three or four months behind,
anywhere from two to four.


Mrs • Whitaker :
You seldom had more than one inspector in a region even
in the last years that you were with the government?


Mr. Cromartie:
No.   We wouldn't have more than one in a region.   You
might take a region of four or five states and have only
                                                            104

one man there.


Mrs. Whitaker:
You were always understaffed then?


Mr. Cromartie:
Yes.   You take five or six statea, it's difficult for
an inspector to cover tha~ many states.      It just gets
down to spot checking.     Of course, they didn 1 t know where
we were going to check and if they didn't know, they were
going to try to keep it under control everywhere.       Not
only that, we could,under the cooperative agreement, if
we didn't have a man in a particular territory and we knew
that a shipment had been made there by some inspector
checking the shipping record, we could request the state
to pick up a sample.     We had twelve or fourteen states
that cooperated fine.     California, Mississippi, Georgia,
Wisconsin, all of them cooperated fine.      They were very
interested in the federal act for the simple reason that
it made it easier for them, since they were dealing with
registered products.     That is, they were going into the
state so they didn't have to do the research work or the
labeling review that we did.      They took our registrations
per se and that was it.     A   few of the states had no pest
control act at all.     If I remember correctly, I think
Kansas was one and Nevada was one.
                                                           105

Mrs. Whitaker:
This was in 1966?


Mr. Cromartie:
Yes.   The main ones on the West coast were Colorado,
California, Washington, Oregon, and Arizona.     They were
in the cooperative program.     Then you got into Arkansas,
they were very cooperative, and Mississippi, Louisiana,
Wisconsin.   I don't think Illinois • • • they might have
had an act but it wasn't very comprehensive.     Whether
they passed another act or not, I don't know.     I imagine
they would though by now.     Quite a few of those states
had acts that went back as far as ours, you know, the
1910 Act, and it wasn•t as comprehensive as that really.


Mrs. Whitaker:
This is a complete change of subject.     Yesterday you
mentioned something I was interested in and did not pursue.
During the time you were a Food and Drug inspector you
mentioned the hydrocyanic acid gas on the dried fruit.


Mr. Cromartie:
What they had to do, they had to fumigate it in order
to keep insects out of the fruit.     The dried fruits were
not only on the docks, they were in the warehouses down
in the fruit growing area.     Of course, they treated them.
The dried fruit would take up the HCN and of course when
                                                        106

they shipped it out they had some poison cases on it.
They had it on raisins.   They had it on all of the dried
fruits for that matter.    It was a tremendous amount of
work at that time spent on checking dried fruit for residue.


Mrs. Whitaker:
What year • • •


Mr. Cromartie:
That would have been around '35 and '36 when they were
having a lot of labor problems on the West Coast.    Harry
Bridges was head of the Longshoreman's union and I guess
still is.   They tried to deport him but the Supreme Court
ruled against them.


Mrs • Whitaker :
He had instigated these strikes • • •


Mr. Cromartie:
And the longshoremen didn't know too much about it really.
I know at that time the salmon industry would ship all
the canned salmon down to San Francisco and put it in
the warehouses.    We did have inspectors up there in Food
and Drug days but then they found it was easier to ship
all the season's pack down there and then sample it at
one time.   At that time I was sampling salmon and it was
in these warehouses.    The canners would furnish the labor
                                                           107

which was longshoremen to handle the cases.     They'd be
stacked up fifteen high and there'd be forty-eight cans
to a case and we only took two cans out of a case.        If
you'd talk to the longshoremen, half of them just went
by what the union said.    And it happened along about
Thanksgiving or Christmas that a lot of them • • . well,
it hurt them at that time of year.


Mrs. Whitaker:
While you were collecting samples of foods, were you
working with drugs also?


Mr. Cromartie:
We were working with drugs.    We'd work with all of them.
You might go out one day and pick up a drug sample, an
insecticide sample, and a food sample, and a caustic
poison sample; it was possible, because they were enforcing
those different acts.     Whatever the assignment happened
to be • • .     You could go in a wholesale drug house and
cover your drug, your caustic poison and then on another
visit to a wholesale grocer house you might pick up a
food sample and an insecticide sample too because insecti­
cides were handled by sqme wholesale grocers.     Well,
you take all of your household sprays, that type, they
handled them.     We didn't do much on the import milk act
at that time; it was pretty well under control.     On the
tea act, they generally had a tea inspector and a tea
                                                           108

examiner but if he got sick or something they might send
you up to sample tea coming in.     I've done that at times.
So you had all the acts to cover.     It was possible, you
could actually cover four acts in one day.


Mrs. Whitaker:
About the caustic poison act, you were, of course, not
in the inspection service at ~he time that was passed.
Do you recall anything in particular.     Who was really
agitating for the caustic poison act?


Mr. Cromartie:
I don't remember who that was.    I think they revised that
after 1940, that stayed with the Food and Drug.      I know
the labeling on certain of the poisons had to have certain
type labeling and certain precautionary labeling.      I don't
actually know who started that caustic poison.     Of course,
I imagine it originally started with children eating lye
and that type of thing.


Mrs. Whitaker:
Lye would not have been covered under the Insecticide
Act unless it were a component of an insecticide in some


Mr. Cromartie:
Or recommended for treatment of inanimate objects which
lye was.   They used it around hog raising places.    It's
                                                           109

a good disinfectant.


Mrs. Whitaker:
And if it had disinfectant qualities or claimed disin­
fectant qualities then you could pick it up under the
Insecticide Act?


Mr. Cromartie:
That's right.


Mrs. Whitaker:
You had to check the labels then as you were picking up
samples.


Mr. Cromartie:
We would only check it for the insecticidal claims or
disinfectant claims, whichever it happened to be.     Of
course, then it could be in violation of both the caustic
poison act and the Insecticide Act, particularly if it
wasn't registered.     Food and Drug didn't require it to
be registered.     If they sent a product in like that to
be registered, it would have to be forwarded to Food and
Drug for them to comment on claims that came under them.
In other words, you had two different agencies that were
involved.   They would have to pass on it too before we
would register it.
                                                           110

Mrs. Whitaker:
That was after 1947?


Mr. Cromartie:
Yes.


Mrs. Whitaker:
During the 1930 1 s and I think as far back as the 1920 1 s
there was a great deal of agitation for requiring a coloring
agent to be put into insecticides which might in some way
resemble food products.     The insecticides were sometimes
mistaken for flour.     Do you recall any experience that
you had with that particular problem?


Mr. Cromartie:
The way I remember it, the arsenical and fluoride dusts
were required to be colored.     Tints of pink and blue.


Mrs • Whitaker:
I think some of the states had laws or amended the existing
laws to require that.


Mr. Cromartie:
Now they did have a few products that did • . • sodium
fluoride, for instance, it had to be a certain shade of
blue.   There have been many people killed with sodium
fluoride, using it instead of flour.     Of course, there
                                                        111


were many of them killed with other products too, I mean,
you know, lack of color.   Sodium Fluoride and the arsenate
dusts are the only ones I can think of right off that
required coloration.


Mrs. Whitaker:
In your inspection work then that would have been one
of the things that your inspectors would have checked
for, I suppose.


Mr. Cromartie:
Yes, and the arsenicals if I remember correctly had to
have a certain hue.    Certain products were required to
have certain hues but I've forgotten.    They had a standard.
They had a color chart that they would compare it with.
Arsenicals and sodium fluoride are the only two I can
think of.   There could have been others.


Mrs. Whitaker:
Have you thought of anything since our last session that
I did not ask you about that you might like to add to this?


Mr. Cromartie:
I couldn't think of anything.    The last I heard the state
cooperative program had pretty much gone out.    They pro­
bably have some kind of cooperative program but what it
is I don't know.   I am not familiar with the latest amended
                                                           112

act.   The last I heard, the last time I talked to anyone
that was familiar with it, they said that the state coopera­
tive program as we had set it up in the late '40's was
nonexistent.      It may be that they increased the number
of inspectors to where they wouldn't have to depend on
outside help.


Mrs. Whitaker:
I do think of one question that concerned the earlier
period.    Do   you recall any discussion concerning an informal
arrangement between the Federal Trade Commission, for
instance, and the Insecticide Division in the days before
rodenticides were covered, that is, before 1947?      I noticed
in the Federal Trade Commission records that the FTC did
occasionally bring suit against a rodenticide manufacturer
for unfair trade practices and that seems to have been
the only control over rodenticides.      Can you recall anything
on that?


Mr. Cromartie:
I don't know of any particular case but I do know that
we cooperated with the Federal Trade Commission.      In
some instances that was about the only way you could
get to false advertising.


Mrs. Whitaker:
To the manufacturers?
                                                        113

Mr. Cromartie:
Yes.   That was at a time that Miller was with the FTC.
He was familiar with both acts.     I don't remember too much
about the extent of cooperation that we had with Federal
Trade except that we did exchange information that way
and they would take action in some instances in cases
that we couldn't.


Mrs. Whitaker:
If you could not touch a product.     Most of the inter­
agency arrangements must have been done on an informal
basis, just person to person, or by telephone., perhaps.


Mr. Cromartie:
That's right.     You would call up and ask them something
and they would give you that information.     At the end
there it got where there were quite a few agencies involved.
There was Food and Drug on the residue end of it and Agri­
culture on the labeling end of it and other agencies too
for that matter.     It got pretty involved at times.


Mrs. Whitaker:
Can you think of a particular instance of another agency
being involved?


Mr. Cromartie:
No, I can't for this reason that most of that would have
                                                        114

been with the registration section because mine was strictly
enforcement after everything had been cleared, either not
registered or found to be in violation.


Mrs. Whitaker:
After 1947 it stopped being a three-man operation as it
had been before.


Mr. Cromartie:
That's right.    It ceased to be.   It kept getting larger
and larger and still is, I guess.


Mrs. Whitaker:
I think we touched on this yesterday about the lack of
attention given to the Insecticide Division or Section
however it happened to be described at a particular time.
When you reverted to the Department of Agriculture, did
it seem that the Insecticide Division was almost a nuisance
to the Department?


Mr. Cromartie:
Well, it was a stepchild, I'll say that.     They weren't
familiar with it.    It was a small organization.   Until
the new chemicals started coming in after '45, there was
very little that the public even knew about it.     You know
when a federal judge doesn't know it, it's not too important.
It was a pretty small organization from 1911 until 1947.
                                                          115

Mrs. Whitaker:
Haywood seems always to have worked very diligently to
keep the Department aware of' the existence of the Insecti­
cide Act.     He seemed to have been a very forceful man.
Did Dr. McDonnell continue that same kind of forceful
attitude?


Mr. Cromartie:
I didn't know Dr. Haywood.     I knew Dr. McDonnell.   If
Dr. Haywood was aggressive to that extent, I would say
that he and Dr. McDonnell were two different personalities
altogether.     Dr. McDonnell was easy going, not aggressive,
so you'd have to have a pioneer or somebody at that time
to push something like that.     We didn't have many in
the Insecticide Division.


Mrs. Whitaker:
Dr. Griffin was not particularly aggressive either in his
relations with the Department?


Mr. Cromartie:
No.   No one was as far as I know from the time that I
went in.    We had to operate . . . we had funds which were
limited.    We had limited personnel and they had to do the
best they could with what they had.     Until all these
spectacular cases came before the public after '45 no
one had ever heard . . • I'd never heard of it until



                                                                -A.
                                                           116

I went with Food and Drug.   Of course, I wouldn't be
supposed to, really.


Mrs. Whitaker:
Food and Drug also was less interested in the Insecticide
Act, I should imagine, than they were in their own act
from the period 1927 to 1938 or    1   40.   It would have been
shunted aside to some extent even there, I would imagine?
Under Campbell's control.


Mr. Cromartie:
At that time they would appropriate so much money for
the economic poison act which I imagine was very small.
The Insecticide Act was larger so they would have to
prorate the inspectors' time on the appropriation he
had.   So they had a lower appropriation, they wouldn't
take an inspector off Food and Drugs to do Insecticide
work because food and drug naturally was more important
and they had a much larger appropriation.         It just got
back to--they had to do the best they could with what
they had, even Food and Drug.     The only advantage was
that they had more inspectors and they could cover more
of it with less time and less expense.


Mrs. Whitaker:
I would imagine there was more public concern with Food
and Drug's activities than there was with yours.
                                                              117

Mr. Cromartie:
Oh, yes.   Food and Drug was always very aggressive.
Campbell, Dr. Dunbar, Larrick, John Harvey, all of them
were very aggressive and they were before Congress all
the time for more appropriations.         Of course, Congress
could see the need of it but I guess they were limited
on funds, too.


Mrs. Whitaker:
Actually the insecticide situation was as significant
in its own way as food and drug was but no one seemed
to have pushed during those years, from 1930 to about
1945, for increased appropriations.


Mr. Cromartie:
Well, it wasn't as big a problem then as it was later
because the number of products involved just weren't·
as hazardous.    You take that list on those annual reports
there, I don't think they had more than 25 or 30 types
of products--the arsenicals, the sodium fluoride., nicotine
preparations., the lime and sulphur solutions.        Right
now they'd be classed very elemental.         They're not com­
parable at all to the number of products now.         I haven't
seen any sodiunt fluoride in years.        I doubt if they use
it for roach control anymore.         As far as I know, the
amount of arsenicals used now is so much smaller than it
was back in the   1   20 1 s.   That's all they had was calcium
                                                               118

and lead arsenate, Paris Green and a few others for fruit
and vegetable and cotton crops.          It's just so far advanced
in the last twenty-five years.


Mrs. Whitaker:
I read somewhere in my research that Paris Green continued
to be used in the late 1940 1 s because of its effectiveness
in the control of mosquitoes.          Did you work any with the
mosquito control program in any way?


Mr. Cromartie:
No.     I didn't know it was used for mosquito control.
It was used mostly for insects.          At one time the main
use was the potato beetle.          They used tons of it for
that but then they got DDT and other things that were
more effective, cheaper too, I imagine.


Mrs. Whitaker:
You were not in the Department, of course, at the time
that calcium arsenate was used so heavily for cotton.
They continued to use that, I suppose, all the way through
the 1930's?


Mr. Cromartie:
Until    1   45.    I sampled carload after carload of calcium
arsenate.          And you wouldn't find one violation in a hundred.
They had it so well standardized that there just weren't




                                                                       1
                                                          119

any violations.    Another reason is the larger manufacturers-­
the main ones that made it, you didn't actually have many
manufacturers of calcium and lead arsenate--would take
the calcium and lead arsenate and mix it up into different
percentages, you know, blend it, they'd use anywhere
from maybe one per cent to ten per cent, I guess.


Mrs. Whitaker:
And most of that was in dust form.


Mr. Cromartie:
In dust form.


Mrs. Whitaker:
I noticed also in my research that there was some contro­
versy in the 1920's about the advantages of dust over
spray and spraying equipment then became available for
liquid applications of certain products.    Was this a
continuing controversy?


Mr. Cromartie:
I don't remember its ever being controversial, that is,
to my knowledge.    Of course, at that tine they hadn't
developed the spray equipment like they have now.    I
don't know whether they even dust down here now.    I think
it's mostly spray material.    I know in the cotton areas
where they have large acreage they can dust.    For the
                                                          120


small crops, very few of them do it to my knowledge.       Of
course, you know you had your airplane-duster of beans,
peanuts, cotton, corn, anything else, and it was so much
cheaper.    To what extent dusting is used now • • • I
imagine it's limited to certain crops and large acreage.
At least I would think from a layman's viewpoint.    All
these orchards in the South, peaches, citrus, etc. as
far as I know there it is mostly spray equipment.    You can
do it so much faster and you can have better control.       If
the wind's blowing,you can't do much dusting.    I guess
you can get better coverage with your sprays anyway.
You take even your small gardeners, 90 per cent of them-­
I guess more than that--they use a spray; they won't dust.


Mrs. Whitaker:
During the 1930 1 s when you were inspecting rather than
acting as an administrator, were those sprays generally
sold in a concentrated form and then diluted by the con­
sumer?


Mr. Cromartie:
That's correct.    The object was why pay freight on water.
And of course they still do for that matter.


Mrs. Whitaker:
That left it up to an uninformed operator to make the
dilution.    Was there a problem with getting the right
concentration on the crops?
                                                                 -i
                                                             121

Mr. Cromartie:
If they didn't follow the directions.     There was one case
where they would have excessive residues after      1   45 even.
If they didn't follow directions, they'd use too much.
Consequently they wound up with residues in excess of
the tolerance on many of the crops and it was just simply
misuse.     If they sprayed or dusted according to directions
for use, the tolerances should not have exceeded that set
by Food and Drug.     They didn't always do that.


Mrs. Whitaker:
As a kind of overview of the whole program, looking back
from 1966, do you think that actually the Insecticide
Division accomplished as much as you were able to, given
the Act that you had to work with and the appropriations
that you had to work with?


Mr. Cromartie:
I would say it did.     I'd say that they covered more than
they could have been expected to because 99 per cent of
them were conscientious workers and they did the best
they could.


Mrs. Whitaker:
Is there any aspect of it that you might have done dif­
ferently or might have recommended that it be done dif­
ferently?     I know this is Monday morning quarterbacking,
                                                            122

 hindsight, but was there any aspect of it that you might
 have handled differently?


 Mr. Cromartie:
 I really can't think of anything that I would have handled
 differently.      The way the conditions were and what you had
 to work with, I don't know how they could have done it
 better, really.     The fact is, I think the Insecticide
 Division, if they had any way of proving it, operated
 as efficiently and productively with what we had to work
 with as any government agency.     When you consider the
 number of people-they had and the amount of money they
 had to work with and you go back to the annual reports
 on what they accomplished, I don't see how they could
 have done any different.     I don't see how they did as
 well as they did.


Mrs. Whitaker:
 I'm inclined to agree with you from what I    have read

to date.     One of the criticisms leveled against the depart­
ment--you know them better than I do probably--was that
there was too much cooperation between industry and govern­
ment in the years after 1945, perhaps to the present time.
Do    you think that industry actually was a hindrance to
you or do you think. that .


Mr.   Cromartie:
No.    I think industry helped a lot because they cooperated
                                                            123


and, as we said yesterday, the associations wanted to comply.
 They wanted standard products on the market.    You will
find these overnight manufacturers everywhere.     You have
it in anything for that matter.     All the time I was in
' Washington to my knowledge we couldn I t have had any kick
, on the type of cooperation that industry gave us.    Of
 course, we worked with the Associations.     The manufacturers
would cooperate when we got:out in the field.      I don't
 know how it could have been any better.


Mrs. Whitaker:
 Then the pressure from the environmentalist groups came
 at a period aC.ter you left.


Mr. Cromartie :

After I left, thank goodness.      Of course, it had started
 two or three years before, a couple of years maybe, when
 Ribicoff . . . you know his investigation.     They only
 had two up until the time I retired, the one Ribicoff
 initiated and then the other one from the Department
 itself.   Of course, that resulted from complaints from
 either the environmentalists or congressmen, the political
 ends of it.    When an agency investigates itself they
 aren't going out, you know, and pick out every little
 detail.   As   far as I know, the Insecticide Division never
 did come up on the bad side.
                                                             124

Mrs. Whitaker:
Can you think of any products that might have been regis­
tered on which there was reservation within the Department,
that you had perhaps not the scientific resources available
to you £o stop registration of any products?       Did you
yourself personally ever feel that any product should
not have been registered?


Mr. Cromartie:
No.     They were vecy careful in those days.    Of course
they found later that they had registered products for
certain uses they shouldn't have but they didn't know at
the time.     They had to work on the data that was available
and on knowledge of the uses.     There wasn't any way you
could correct that.     In other words, time.    Many products
on the market used years and years ago are not in use any
more.     You take back in the old days, turpentine and castor
oil used to be a general family remedy.     I don't think
they ever use turpentine any more for medicinal purposes.
They learn by experience.


Mrs • Whitaker :
Some of the criticism then would not be justified simply
because you did not have available to you . • •


Mr. Cromartie:
There was nothing you could do about it.        Of course you'd
                                                         125

stop the use of these chemicals like they have DDT.      They
can't stop them all.   Aspirin you know has killed more
people than insecticides.   You just can't say this or that
should or shouldn't be used.


Mrs. Whitaker:
Were you ever personally called upon by any congressman
or representative of any of the environmental groups or
ecologists that you can recall during your last years
there?   Did they ever come to the agency and talk with
you or Dr. Griffin or Dr. Reed about perhaps amending
the Act as it stood?


Mr. Cromartie:
Not at that time.   I don't remember any.   The only dealings
we would have with the congressmen would be where some
of their constituents complained and then the congressman
would want to hear both sides of it.   They had to satisfy
the constituents too so we had to satisfy the congressmen.
We didn't have too much of that.   It was pretty well cut
and dried.   The only experience I would have had, anyway,
would have been the enforcement end of it and of course,
we had that all the time.   The congressmen never gave
us any problem on the enforcement end of it.    I had to
go up and talk to one or two congressmen about some of
it but once they saw what the situation was there wasn't
much they could do about it.   They passed the law, we
                                                          126

didn't.   The experience that we had during the time that
I was there was very reasonable.     They weren't trying to
put pressure on you not to prosecute this man or don't
seize anything like that.    If his constituent called him
or wanted him to do something, they had to do the best
they could.    The whole time that I was there up until
the very end things were working very smoothly.     Of course
they got more complex and are still     getting more so, I
guess.    Outside of the pressure from the work and the
limitations you had on personnel and funds, things were
very smooth.     If I had to do it over again, there are
very few things that I think of that I'd do differently.
The fact is, I can't think of any.     Of course, I made
plenty of mistakes.


Mrs. Whitaker:
I'm sure you could not have made very many to have come
through with as fine a record as you have.


Mr. Cromartie:
That's questionable too.


Mrs. Whitaker:
I can't think of any more questions now.     I'm sure I will
have some when I reach home.


Mr. Cromartie:
If you do, just write them down in longhand and send them
                                    127

down and I'll try to answer them.
                                          128

 Agricultural Research Service, 32
 Airplane dusting, 120
 American Medical Association,       Bo
 Appropriations, 29, 70, 99
 Arsenate of lead, 12, 26, 27, 118


 Bureau   or   Animal Industry, 25


 Calcium arsenate, 118
 Campbell, Walter, 2, 13, 25
 Caustic Poisons Act, 108
Coloring Amendment, 110
Coyne, John, 30
Cromartie, A. D., as inspector, 1,
   7, 44-46, 61, 98, 103, 107; in
   court cases, 9, 19; retirement,
   33; as administrator, 34, 35,
   97; under FIFRA, 41; dealing
   with manufacturers, 47


DDT, 50ff, 85
Department of Agriculture, S, 29.,
   49, 114; Insecticide Division,
  3; Livestock Branch., 2, 3, 29;
  Bureau of Animal Industry, 25;
  investigates Insecticide Division,
  32, 123
                                               129

    Disinfectants, 10, 12, 13, 18, 25,

I      57, 58-60, 76, 89, 94, 109
    Dried fruits, 105


    Environmentalists, 125


    Factory Inspection, 15, 16, 17,
       92-94
    Federal Insecticide, Fungicide and

I      Rodenticide Act, prosecutions
       under, 37; court cases, 78, 82;
       writing of, 49; registration
       under, 55ff, 60, 69, 124; labeling,
       57, 66; tolerances, 66; laboratories,
       67; use and application provisions,
       73-74; registration under protest,
       80; DDT, 87; State cooperation
       program, lOOff; attitude of USDA
       toward, 114; effectiveness of, 121
    Federal Trade Commission, 112
    Food and Drug Ad.ministration, 13,
       116; inspection under, 6, 8, 15,
       27, 107; contact with consumers,
       27; court cases, 12; investigations,
       62; and cranberry cases, 64; tol­
       erances, 65
    Food, Drug & Cosmetic Act: tolerances,
       8; court cases, 10, 20, 78; intent
                                         130

    to defraud, 22; seizures, 25;
    and Miller Amendment, 62
 Food, Drug & Insecticide Administra­
    tion, 25
 Flea killers, 23
 Fungicides, 15, 76, 82


 General Counsel, 11, 21, 28
Griffin, E. L., 5, 9, 23, 29, 30,
   49, 75, 97


Hays, Harry, 33, 39, 62
Haywood, J. K., 15, 20, 115
Health hazards, 71-72, 83, 86, 117


Insecticides, 6, 12, 15, 18, 19, 24,
   43, 55, 82
Insecticide Act of 1910: penalties
   under, 19, 20; court cases, 21,
   22; seizures, 25; pressures under,
   35; and DDT, 50-53; limitations, 73
Inspection, 1, 14, 16, 34, 42-46


Lindane vaporizers, 79


McDonnell, C.   c., 2, 4, 5, 30, 115
Manufacturers, 89
                                       131

Manufacturers' associations, 48-50,
   123
Miller Amendment of 1954, 62, 66
Miller, Lowell, 21, 39


National Academy of Science, 33
Notices of Judgment, 20, 88


Paris green, 118
Pesticides: health hazards, 71-72;
   environmental hazards, 72
Public Health Service, 60
Pyrethrum, 17, 28


Reed, Harry, 29
Reed, Webster, 2, 29, 30, 97
Rodenticides, 36, 68, 112
Rotenone, 17


Salmon: inspection of, 105
Secretary of Agriculture, 31, 70,
   84
Seizures, 25, 90
Silent Spring, 84
Solicitor's office, 10-11, 23, 38
Spray residues, 4, 6, 8, 33, 52, 85,
   106, 121
State Cooperative Program, 100ff
                          132

Tolerances, 65


Ward, Justis, 30
Weed-killers, 72-73, 82
WW II, 18