March 23, 19706

The HO@n. John Sarman

Chairman, Subcommittee on PUblic Health and Welfare
House Committee on Interstate and Foreign Commerce
House Office Buiadding

Washington, D. C. 20515

Dear Mr. Jarman:

I am writing in reference to H.R. 12751, having noted that testimony offered
by Representative Patsy T. Mink as published in the Congressional REcord for
March 11, 1970.

Mra. Mink must be commended for having brought the attention of the Congress

to the problem of glue~sniffing and similar abuse of other solvents, quite
correctly comparing this to other serious areas of drug abuse. The unhindered
availability of solvents does pose a very serious problem in protecting juveniles
from very serious injury to themselves with respect not only to behavioral
aberrations, but also well documented odds of serious damage to the liver and
other internal orgens. The wide variety and uncertain composition of many
solvents subject to this abuse greatly compound this problem. It might indeed
be most helpful if safe repellent additives could be found that would deter
sniffing.

My concern is whether we have sufficient reliable information about any com-
pound now proposed for use as a deterrent to be gure that it does not become

a serious environment pollutant and end up possibly casming more damage than
the situation it is supposed to remedy. Yhe denaturation of glue is not likely
to be a total answer to the solvent-addiction preb@em, but it would undoubtedly
lead to the exploitation of other solvents like gasoline. The possible escala-
tion of the list of products for which the incorporation of a deterrent is
indicated should obviously heighten our concern about the safety of such addi-
tives.

The underlying technical problem is very similar to that involved in the develop-
ment of safe but effective "harrassing agents" like tear gas intended for use

in riot control, some military situations, and subduing violent behavior. As

has been well publicized, none of the existing compounds, for example, chloro-
acetophenone as ie used in MACE, is really quite satisfactory, and they would

be even less so where the standards of potential harm to people subjected to

the agent must be set even more stringently.

 
Hon. John Jarman March 23, 1970
Page 2

Mrs. Mink's testimony does not offer any technical details, nor have I had

an opportunity to see other testimony that may have been offered to your
subcommittee. However, the Festor Corporation, mentioned in her presentation,
has announced the possible utility of mustard ofl, allylisothiocyanate, has

a deterrent additive. I am enclosing an article that I wrote some time ago
in response to that suggestion. I must say that at the present time I feel
that I was too timid in criticizing the use of allylisothiocyanate for this
application, perhaps through not having visualized the eventual possibilities
of its expanded use in the future. I had also not been able to find, until
very recently, some of the pertinent literature on the biological effects of
this compound, copies of which are also enclosed. These studies are not neces-
sarily the final answer to this inquiry, but they must point to the necessity
of very careful validating studies.

It may be answered that mustard oil must be safe since it is a natural constituent
of horse radish and other condiments. It is not mk intention to open the question
of the significance of these articles of diet for health; although some interesting
issues might be raised, I do not regard them as having a very high priority. It
must be stressed, however, that the application of mustard oil to the skin and by
inhalation together with any of a variety of organic solvents present issues of
possible toxicity which are not fully answered by studies on a dietary component
which enters the body under the influence of digestive processes and in combination
with a very different set of other materials.

My specific recommendations on H.R. 12751 are:

(1) That no additive be permitted to be used or advertised as a deterrent
against solvent-sniffing until the Secretary of HEW has found that it
has been rigorously tested and can be assured to be ffee of toxic hazards
(including chronic effects, cancer, or teratology), and

(2) That the mandatory provisions not be invoked until the safety of such an
additive can be averred. I also believe that the Secretary should be
given discretionary authority to decdde whether the incorparation of a
deterrent to a particular class of products will have such benefits as to
warrant the rule.

This discussion also brings up other areas of product safety beyond the inmediate
scope of H.R. 12751, which I would nevertheless commend to your attention:

(1) The need for regulation on safety grounds of tear gas and related products,
especially if these are to be made available on the public market, and

(2) Product safety, identify, and purity standards for solvents on the general
market whose inadvertent inhalation may represent a health hazard.

Finallym I would be grateful to you for copies of other testimony on the questions
raised in this letter, and I would welcome an opportunity to comment on any
submissions that may be within the scope of my professional competence and interest.

Sincerely yours,

Joshua Lederberg
ec: Hon. Patsy Mink Professor of Genetics