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J.

P..Fra

A. Miller
Pi.
Miller - Hercules
J. A. Zapp, Jr. - Du Pont
V/. E. McCormick - ,3. P. Goodrich

E. I. du Pont de Nemours & Company
Wilmington, Delaware 19698

LEGAL DEPARTMENT

March 5, 1970

Mr. Morgan M. Hoover
Manufacturing Chemists Association
1325 Connecticut Avenue, N. W.
Washington, D. C.
20009
Dear Mr. Hoover:
Your February 24, 1970 transmittal to the full committee
has certainly struck a responsive cord. .Carrol Weil of the
Mellon Institute had certain reservations as to the first page
and a half of our draft statement and discussions with V,Teil and
Jack Frawley lead Jack to prepare a new'version (copy attached)
which in my opinion seems much better than the previous draft .
circulated by your February 24 letter.
John Zapp is now in
Europe so I speak only for myself in this regard.
The new version seems to go a long way in resolving
Ken Mulford's and Carrol Weil's objections.
If both Mr. Mulford
and Mr. Weil can find the new version acceptable, there only
remains the resolution of the technical drafting question to
make sure that our suggested proviso applies to both, parts of
the Delaney Amendment.
As you may know, Delaney Amendment language also appears
in the Animal Drug Amendment (Section 512 of the F D & C Act) and
the Color Additives Amendment (Section 706 of the F D & C Act).
We will have to add a sentence making it clear that the MCA comments
apply equally to these other sections of the Act as well as to the
Food Additives Amendment.
I think Merck's reaction as well as in part Carrol Weil's
and even to some extent Ken Mulford's is due to the fact that they
were not advised in your transmittal letter of the three Finch
questions which the draft statement was intended to answer.
None­
theless,, the substance of their comments suggests to me that we
would probably be making a mistake in attempting to answer Finch's
questions as posed.
S! “L. C^)CO(M)

ASI 00002403

Mr. Morgan M. Hoover

-2-

March 5, 1970

As Mr. Weil has been supplied a copy of the revised
draft by Jack Frawley and Mr. Mulford by copy of this letter, I
assume we can expect to hear further if the revised draft is not
satisfactory.
X think it would be in order if you vrould supply
a copy of the revised draft to Mr. Mennis at Merck to determine
if this revision lessens in any way Merck's concern.
Very truly yours.

/

Taylor

/

/

/

/

Hanavan

TWH:bjd
Att.

ASI 00002404