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179  Test for Safe Products
     The Washington Post  November 22, 1969

     In recommending the strict regulation and gradual phasing-out of
DDT, Health Education and Welfare Secretary Robert H. Finch has made a
difficult, but I believe correct, choice among several options.  Our 
environment is already heavily contaminated with DDT.  Human exposure
to it will scarely be affected by a restricted level of continued use,
for a few years.  Meanwhile, we should seek formulas for rational
decisions about, say, health-related applications, whose benefit might
outweigh the measured risks.  We should not neglect standards for
foodstuffs to eliminate those which are so heavily contaminated that 
they add an unreasonable extra burden to their consumers.

     We might also ponder whether to look for those people who have
the heaviest DDT loads and investigate the benefits and risks of
medically supervised treatments to wash out the pesticide residues
that now average more than 10 parts per million in human fat tissue.
These measures my be more drastic than existing evidence of harmful
effects of DDT to man would justify.  It would be preposterous to
await this level of proof before controlling the use of the pesticide.

     The DDT and cyclamate episodes should move us to hard thinking
about preventing similar ones before they have gone so far. In 
scheduling our priorities, we probably should concentrate on pollutants 
that are the most widely spread, emanate from a limited number of
sources, and tend to accumulate chronically within the body.  These
criteria are almost a definition of the lead from auto exhausts -- 
the mere fact that the lead is accumulating in human bones is enough reason
to ban the use of lead additives in gasoline before we discover the
full magnitude of its impact on human health.

     We also need new approaches to the testing of environmental
additives, be they related to drugs, food, pest control or fuel. 
Existing procedures lay the full responsibility (if any) on the
industrial sponsor of a product. A government bureau then has the
unpleasant task of policing the "proofs" of safety, which must be
done in a framework of rigid bureaucratic regulations.  The evidence
is also rarely accessible to general scientific criticism.  The system
is then heavily burdened by pressures of self-interest, and suspicions
thereof, which repel creative investigators. Only after a product has
been certified and marketed is it likely to receive aggressive, 
independent criticism.  This is unfair, even to the manufacturer who has
committed his reputation to a product before it can be properly 
tested, not to mention the public interest.

     Senator Gaylord Nelson has proposed a big step in the right
direction in his bill for a national drug testing center, an idea that
could readily be extended to other additives.  This would be supervi-
sed by the Food and Drug Administration, but test operations could be
subcontracted to other institutions.  The cost would be paid by the
sponsors of the drugs.  This approach should allow much greater 
flexibility on the part of an independent testing center for deciding 
which tests are most appropriate and necessary.

     This bill could be improved by incorporating incentive features,
for example, a standard fee related to population exposure rather than
the cost of testing.  And the sponsor should get a rebate if his pro-
duct was found harmless; pay a penalty if the testing center discove-
red a hazard before the sponsor did.

     We could then exploit some of the inherent advantages of free
competition, which are a drag on the present system.

     The cost of adequate testing is inevitably a burden on innovation
and when it pushes a sponsor into prematurely marketing a product, it
may do public harm.  We ought to think of tax incentives and subsidies
to the testing center as positive remedies and penalties for 
carlessness as negative ones.  Finally, we ought not give the purveyors
of products "generally accepted as safe" an unfair advantage when these 
have not been fully tested either.
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