f Ered Mhdpare

December 29, 1976

Dr. Michael Jacobson

Center for Science in the Public Interest
1757 S Street, N.W.

Washington, D.C. 20009

Dear Dr. Jacobson,

This is in reply to your letter of December 13th concerning food
additives. The best I can recall the quotation is a paraphrase, that
appeared with my approval in a popular magazine, of the position that I
aggued at greater length in my article that appeared in "Hoe Safe Is Safe?"
I guess my position is possibly more complicated than you would prefer, but
I recommend that you read the article to get an account of it that I think
I would still adhere to. I had an interesting debate at that time with
Jim Turner and had been pleased to be able to continue that discussion from
time to time.

As I said, it is not easy to summarize my position. But perhaps it
might go something like this: the Delaney Amendment is a scientific
monstrosity, but at least until recently has manifestly worked very strongly
in the public interest. I would hope that we could come up with some still
more rational solutions to the problem of balancing special interests,
public hazards, benefits and risks; but until some clear-cut alternative
is available, I would certainly not advocate revoking the amendment. Un-
fortunately we seem to be living in such an adversarial climate that
criticism of the detail of a given approach is likely to be mistaken for
a binary choice.

I can see what you have to complain about in the general thrust of the
fleneral Zoods' propaganda. But I would be curious to know just what it was
about the statement they chose to quote that you disagree about. Or is it
just the identity of the quoter. .

On another occasion, I wrote to commissioner Schmit and suggested that
he attempt to impose an overall ban on all synthetic food colors regardless
of the present state of evidence about their safety. My argument was that I
did not believe that we had any scientific methodology that could convincingly
prove that one color was safer than another and that the public was therefore
being misled by the succession of individual actions and we were all-
together being led through an extremely unproductive and painful series of
decisions that strained the very limits of scientific validity. It would be
more sensible, in my view, for the public to face the decision whether
synthetic colors as a class have sufficient utility to be worth retaining
or whether we would not be better off dispensing with them altogether in the
light that any of them had essentially untestable potential hazards and the
manifest benefit was so slight. Perhaps at some later date it may be possible

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to develop tests with greater sensitivity and scientific validity that could
assure us about the relative safety of such synthetics, but at the present
time I would submit that the cost of investigation probably exceeds their
economic utility. At least this is a policy issue that I believe would be

a more honest confrontation with what is at stake than what has been going on
up until now.

Less you misunderstand me, my personal vote would be to exclude such
colors. But this is based even more on my own low appreciation of their
utility than it 1s on any sense of real hazard from their intake. I would
not want to impose my preferences on others without their having an informed
opportunity to cast their own vote.

I am also sensitive to the extent to which the imbalance of power in
the marketplace constrains the hypothetical "free choice" of the consumer
to decide whether of not to intake food additives. I wish I could find a way
in which that problem could be ameliorated on its own merits rather than
oblige us to seek preemptery regulation that makes such decisions on behalf
of consumers. I have no very good ideas on that question, but something along
the lines of the EPA policy that at one time mandated that lead-free gasoline
at least be made quite generally available might be a basis for some further
thinking about the food additive question.

These remarks were intended as a personal response. I have not sppnt
a great deal of time thinking about how they might be viewed or possibly
misinterpreted by others. So, I hope you will not use them further without
consulting me about it.
Sincerely yours,

Joshua Lederberg
Professor of Genetics

JL/rr
Enclosure