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11/16/2012
“Harvey Wiley’s
‘Poison Squad’: Food Additive
Safety
Wiley’s “Poison Squad”/ Hygienic Table
 Borax (boric acid)
 Salicylates (salicylic acid)
 Sulfites (sulfuric acid)
 Benzoate of Soda (sodium benzoate)
 Formaldehyde
 Saccharin (sweetener and preservative)
SUZANNE W. JUNOD, PH.D.
U.S. FOOD AND DRUG ADMINISTRATION
HISTORY OFFICE
[email protected]
 Potassium (curing meats)
 Copper sulfate (“greening” vegetables
Washington Post, December 21, 1902
WILEY ADDS BORAX
After many false starts and various set backs,
preservatives in food for the 12 scientific boarders at the
Bureau of Chemistry, Agricultural Department, were used at
dinner last night for the first time.
They ate together for
some days before adding the first of the preservatives to be
tested – borax.
It was “stewed with the food” which
consisted of roast beef and gravy, potatoes, vegetables, bread
and butter, milk and tea.
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The Poison Squad’s Significance
 Wiley confirmed his own prejudices.
 There was universal agreement on the dangers of formaldehyde.
 There was little agreement among scientists about the significance of
Wiley’s other experimental findings.
 Wiley’s conclusions put public health concerns at the forefront
COMMON SENSE IN THE HOUSEHOLD
 Poison squad participants learned that eating a high quality diet,
replete with fruits and vegetables, can counteract any ill effects from
preservatives.
This isn’t Joan of Arc at the battle of
Orleans. It is only young Mrs. Dupagnac
at the siege of tomato catsup; and
possibly, she may save one bottle if the
fermentation is willing.
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The 1906 Act – 27 Years in the Making
Overall Intent of the 1906 Pure
Food and Drugs Act
PROTECT AND ELEVATE THE
FOOD AND DRUG SUPPLY AS
WELL AS REPUTATIONS OF
HONEST BUSINESSM EN BY
WEEDING OUT DISHONEST
PLAYERS
Key Provisions of the 1906 Pure Food
and Drugs Act
 Commerce Clause in the Constitution:
 Jurisdiction over goods moving in interstate commerce
Key Provisions of 1906 Pure Food and
Drugs Act (cont’d)
 Defined adulteration
 Defined misbranding
 Scientific investigations and enforcement authority
vested in Bureau of Chemistry, USDA
 Condemned products subject to seizure and
destruction at defendant’s expense
 Violations incur misdemeanor - $500 for first
offense; $1000 for second offense
 Publication of Notices of Judgment as a deterrent
Key Food Provisions Under the 1906 Act
 Prohibited “added” poisonous or deleterious
ingredients (poisonous minerals, colors, flavors)
 Prohibited omission, substitution, or mixture of
ingredients that would lessen value, quality, etc.
 Required accurate labeling : tell the truth or be
silent as to weight, quantity, country of origin, etc.
 Prohibited food made up “in whole or in part of
filthy, decomposed, or putrid” substances
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Theodore Roosevelt’s State
of the Union Address, 1907
“Two years have not elapsed, and already it has
become evident that the great benefit the law
confers upon the public is accompanied by an
equal benefit to the reputable packing
establishments. The latter are better off under
the law then they were without it.”
Chemogastric Revolution
Food Advertisements in Good Housekeeping
1940
 Before WWII
 Average of

26 per issue
1950
 After WWII
 Average of
68 per issue
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Intent of Delaney Laws
 Populist response to growing concerns about
the safety of “manufactured foods” and
pesticides.”
 “Functional food additives” (emulsifiers,
preservatives, cleaners) with complex
chemical names were unfamiliar.
 JUST SAY NO!
Delaney Laws
 1954 Miller Pesticides Amendment
 1958 Food Additives Amendment
 1960 Color Additives Amendment
Delaney Clause and Regulatory Limitations
– Color Additives
 “No additive shall be deemed to be safe if it is
found to induce cancer.”
 Orange #17 presented a lifetime risk of cancer
of 1 in 19 billion.
 Courts rejected FDA’s “de minimis” argument
leaving FDA “helpless slaves to literalism.”
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GRAS List
Generally Recognized As Safe
Miazga’s Discovery
“Death is nature’s way of telling you the FDA was
right.”
Robert Miazga, The Official Explanations
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