TELEPHONE HUDSON 3 6126

Manufacturing Chemists’ Association, Inc.
(FOUNDED 1872)

1825 Connecticut Avenue, N. W.
Washington, D. C. 20009
March 21,

TO:

Members of the Food,

SUBJECT:

Drug,

1967

and Cosmetic Chemicals Committee

Request for Data on Indirect Food Additives

Gentlemen:
Following up my letter of February 28 on the same subject,
am enclosing a copy of Dr.

I

Frawley's letter which clarifies the

type of information needed.
Sincerely yours.

Morgan M. Hoover
MMH:sjg
Enclosure

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MERCULSS INCORPORATED
MEDICAL DEPARTMENT
■ERCGLES TOWER

•

910 MARKET STREET

•

WILMINGTON. DELAWARE 19899

•

(3021 656-9811

March 17, 1967

Mr. Morgan M. Hoover
Manufacturing Chemists' Association, Inc.
1825 Connecticut Avenue, N. W.
Washington, D. C. 20009
Dear Mr. Hoover:
I have noticed from an exchange of correspondence between
Bill McCormick and you that there is a bit of confusion regarding the
type of information which I am collecting for added support to the thesis
proposed last September at the ACS meeting.
I understand that Bob Miller sent you sufficient copies of my ACS
paper for distribution to the FDCC Committee.
In this presentation, the
conclusion that anything used in food packaging at a level of 0.2% or less
was safe, was based on two other scientific conclusions. I would welcome
support from the industry for both of these conclusions.
The first of these conclusions; namely, that chemicals which might
be used in food packaging would have a "no effect" level in experimental
animals of 10 ppm or greater, was based on a compilation of published
two-year chronic toxicity studies. A number of companies have sent me
additional unpublished studies and I would welcome others from the industry.
To include them in my tabulation I need the name of the compound, the species
of animals used, and the highest level which caused no toxicity.
The second conclusion was based on the argument that rosin size
would give the highest migration to food of any food packaging component.
I would appreciate receiving supporting evidence from any companies who have
conducted migration studies which demonstrate true migration to food.
I
expect that few studies of this nature have been conducted since most
laboratories have used simulated solvents rather than food or vegetable oils.
I am aware of several studies being conducted in this area, but if others have
data on hand it would be very helpful.
I understand that Bob Miller received a warm reception by the FDCC
Committee on January 25.
From all indications my presentation of this concept

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Mr. Morgan M. Hoover

Page 2

March 17, 1967

in England and The Netherlands was well received. There is even a suggestion
that the concept might be adopted in the European countries before anything
is done in the U. S.
If I can provide any other information which will clarify the type
of supporting information which would be helpful, please let me know.
Sincerely,

jo;
Chief Toxicologist
JPF/eaw
CC:

Mr. W. E. McCormick

ASX 00002175