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EXHIBIT S

THE AMERICAN PUBLIC HEALTH ASSOCIATION, INC.,
Washington, D.C., July 11, 1966.

enator ABRAHAM RIBICOFF. enate Office Building. Vashington, D.C.

DEAR SENATOR RIBICOFF: I am attaching a copy of a letter addressed to the Honorable John Gardner, Secretary. Department of Health, Education and Welare which conveys a concern of the American Public Health Association relative o Reorganization Plan 3 Because you have expressed a similar concern I elieve you may be interested in knowing of our Association's expression. Yours truly,

BERWYN F. MATTISON, M.D.,

Executive Director.

THE AMERICAN PUBLIC HEALTH ASSOCIATION, INC.,
Washington, D.C., April 29, 1966.

Hon. JOHN GARDNER,
Secretary. Department of Health, Education, and Welfare,
Washington, D.C.

MY DEAR MR. SECRETARY: I am writing about the recently announced plan for reorganization of the Public Health Service. You will recall that on November 22nd, 1965 Dr. E. L. Stebbins, of Johns Hopkins, and other officers of this Association met with you to discuss various concerns in the field of Delivery of Better Health Services to the People of the Nation. At that time and later in talking with Professor Corson we emphasized a point which has apparently been ignored in the re-structuring of the Public Health Service. Because it seems to us to be so vital to the future of community health in this country, we are re-stating it. Man today more than ever before is influenced by his external environment. Society is now doing more than at any other time in history to defile the environment, and yet at the same time we have the technology sufficient to influence environment more than ever before for Man's benefit. The impacts of the external environment and Man's internal milieu on his health and well being are inextricably intertwined. Programs which influence one or the other of these two media in which Man must live should not be dissociated, but planned and carried out in an integrated or at least well coordinated fashion.

However, to do this requires two different kinds of professional disciplines; for the external environment, a complex and highly professionalized group of engineers and physical and chemical scientists have been developed; for delivery of personal health services, both preventive and curative, we have medicine and the related health professions.

It is our considered belief that Federal programs with a direct responsibility for health should be primarily based in the Public Health Service. This means top level professional leadership by a physician-The Surgeon General. But it is unrealistic to expect the continued development and maintenance of top level engineers and physical and chemical scientists to participate in the highly significant field of Environmental Health unless their contribution is recognized and stimulated by proper organizational placement. The new organizational structure does not appear to accomplish this end. I should like to suggest again that you consider the importance of environmental health from the standpoint of its separate and special technologies and professional manpower-and re-examine the proposed Bureau structure with this in mind.

A contained splintering of and dispersion of environmentalists' skills is inevitable unless the Public Health Service establishes a structural position for those practitioners of environmental health who have contributed so much to our public health programs in recent decades.

Sincerely yours,

BERWYN F. MATTISON, M.D.,

Executive Director.

EXHIBIT 9

INTERNATIONAL ASSOCIATION OF
MILK, FOOD & ENVIRONMENTAL SANITARIANS, INC.,
Shelbyville, Ind., July 12, 1966.

Senator ABRAHAM RIBICOFF,

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Chairman, Subcommittee on Government Operations, New Senate Office Building, I a Washington, D.C.

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Healt DEAR SENATOR RIBICOFF: It has come to our attention there are certain plans of for the re-organization of the Public Health Service, in which Environmental Health would become a section in a new Bureau to be known as the Bureau of Disease and Injury Prevention. The

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I can assure you our several thousand members will take a very dim view an of such a plan. Most of us have devoted many years to the work of improving the our milk, food and environmental sanitation under health and agriculture de- pons partments of various states, in cooperation with the Public Health Service. ma The proposed plan would completely disrupt this tried and proven program Ho throughout the states.

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The truth is the one great improvement that could be made is to put more responsibility and control of environmental health into the hands of the pro- cal fessional sanitarian who is far better qualified to direct sanitation than persons те with medical training only. It certainly is not wise to adopt a program in which medical direction is even more emphasized.

Our annual meeting is to be held in Minneapolis, Minnesota in August, and I am sure a resolution from the membership will be forthcoming.

I wish to commend you on the stand you took at the May 27, 1966 hearing of your sub-committee.

Sincerely,

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Hon. ABRAHAM RIBICOFF,
Chairman, Senate Subcommittee on Executive Reorganization, New Senate
Office Building, Washington, D.C.

DEAR SENATOR RIBICOFF: I am writing to you as Chairman of the Conference of State Sanitary Engineers, members of which as you know generally represent environmental health programs in their respective states.

We have been greatly impressed with the direct approach that you are taking in your hearings with respect to reorganization of the U.S. Public Health Service, and more especially, the environmental health activities. We agree wholeheartedly with your recognition of the need for a visible environmental health program in the reorganization of the Public Health Service. This visibility. together with competent engineering leadership, is dictated by the present and future environmental health programs and the realization of their impact by the citizenry generally.

Attached for your information and for your record is a position statement of the Conference of State Sanitary Engineers presented before the Dawson Committee on this same subject.

If at any time our interested and concerned members can be of assistance to you in developing an effective environmental health organization at the Federal level, we would consider it a pleasure to serve you.

Sincerely yours,

H. L. THOMASSON,
Executive Secretary-Managing Editor.

OSITION STATEMENT OF CONFERENCE OF STATE SANITARY ENGINEERS ON REORGANIZATION PLAN No. 3-REORGANIZATION OF HEALTH FUNCTIONS OF THE DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE

Mr. Chairman and members of the committee:

I am Meredith H. Thompson, Assistant Commissioner for Environmental [ealth Services New York State Department of Health, and chairman-elect of he Conference of State Sanitary Engineers. This statement is presented for the Conference of State Sanitary Engineers an organization consisting of the state anitary engineers of each state, the District of Columbia, Puerto Rico and the irgin Islands.

The Conference of State Sanitary Engineers supports the Re-organization Plan of the President. In recent years, it has been evident that the organization f the Public Health Service is outmoded by changing problems and new reponsibilities. The concept of providing authority for the Secretary of HEW o make changes from time to time is sound.

However, we have strong reservations about some of the features of the proosed reorganization, itself, as we understand it.

Concern by your commitee, the congress generally, federal agencies, state and ocal governments, the people of the United States and our conference for effecive presention and control of all environmental health factors means these actors have significance and are of major importance to our communities. Enironmental health activities logically must be carried out at the state and local evel. However, competent, identifiable leadership for environmental health rograms is a must at the federal level. Now is the time that more emphasis, dentity, coordination and action must be given environmental health programs. A federal government organization is needed which by name will identify he environmental health programs but more important an organization of suficient stature that it can be headed and staffed by the best qualified environnental personnel available.

A Bureau of Disease and Injury Prevention and Control as proposed does not meet important criteria of our conference for an effective, active environmental ealth federal government organization.

The Conference of State Sanitary Engineers appreciates this opportunity to present a statement and will be pleased if we can be of any further assistance to your committee on this important matter.

terest in many governmental areas in 1960, many of us who have been involved actively in this area are now concerned that the integrated approach, referred to above, will become so fragmented that an over-all fundamental attack on environmental health problems may prove to be very difficult.

Because of this situation I wrote Dr. John W. Gardner, the Secretary of H.E.W., this past March about the matter, in view of the proposed reorganization of the Public Health Service, which I presume by now Congress has authorized him to proceed with. Rather than going over the same ground in this letter to you, I am enclosing a copy of my letter to Secretary Gardner. which sets forth the direction which many of us concerned with this area feel should be taken in relation to any reorganization of the Public Health Service. I gather from Professor Chanlett's letter to me that your own view of the proper course which this reorganization should take is close to that which I have expressed in my letter to Secretary Gardner. Furthermore, developments in the past few days and weeks indicate to me that it is important to have this view strongly presented in relation to the proposed reorganization of P.H.S. The most recent plans of which I am aware are that the Public Health Service would contemplate combining its activities in the environmental health field, together with those of the present Bureau of Communicable Diseases, in some type of combined organization, as yet, not clearly defined under the title of a Bureau or element within the Public Health Service to be known under the title of Disease Prevention and Environmental Control. In my own judgment, this coalition is a move in the wrong direction nad will surely de emphasize the importance of the environmental health sector. Many of those in the professions concerned, labor and community groups involved have become aware of the hazards which we face from the environment and have associated these with the term "environmental health." To dilute this now within the activities of the Public Health Service would, in the view of many of us, result in the loss of much ground that has been gained in focusing government and public attention on the over-all problem in recent years. Furthermore, as I point out in the enclosed letter to Secretary Gardner the segment of the scientific and technical professions which has done so well in the disease oriented activities of N.I.H. and the communicable disease center is not the most appropriate group to give the needed leadership in the environmental health areas where the problems range all the way from the natural and physical sciences through many of the disciplines of the social sciences. Those of us interested in the matter are indeed pleased to learn of your own interest and activities in assuring that a sound, federal structure will be developed so that effective federal leadership can be given to the many agencies that are now deeply concerned with the broad and complex problems of the environmental health area.

Very truly yours,

PAUL GROSS,

William Howell Pegram, Professor Emeritus of Chemistry.

Hon. JOHN W. GARDNER,

Secretary, Department of Health, Education, and Welfare,
Washington, D.C.

MARCH 23, 1966.

DEAR JOHN: Knowing the pressures which you must be under, in view of the expanding activities of H.E.W., it is with some hesitation that I write to bring to your attention some current trends in the area of environmental health activities. I do so not in my present capacity as a member of the National Advisory Environmental Health Committee, but as one who has been heavily involved in various advisory capacities in this area since I was asked to chair the former Surgeon General's Committee on national environmental health problems in August, 1961. It is from this standpoint that I am passing on to you the following comments.

1. In the Fall of 1961 when the report of the Committee, referred to above, was issued, there were encouraging signs of increasing interest and concern in the mind of the public, and even in Congress, about the development of effective measures to meet the rapidly mounting problems in the environmental health area. Following the issuance of our report I was involved in a number of hearings and discussions with top level advisory scientific groups and representatives of the Bureau of the Budget concerning federal planning for action in the area. In relation to these, I would be less than frank if I did

not say that I encountered considerable lethargy and lack of understanding in the scientific and technical groups involved, though not in the Bureau of the Budget, about the nature and magnitude of possible courses of action which should be taken with respect to federal activity and support in this area.

2. The five years that have elapsed since have seen a dramatic change in this attitude. This is perhaps best typified by the recent issuance of the P.S.A.C. Panel Report endorsed by the President, entitled "Restoring the Quality of Our Environment," and by the various acts passed by Congress during the past several years. Those of us who have been heavily involved in discussions relating to this area are greatly gratified by this broadened interest and concern.

With these remarks as background, let me return to the matters which bring me to write you at this time.

3. Our Committee in 1961 was broadly representative of a wide scope of interests concerned with the changes taking place in our environment. Its members included those interested in recreation, wildlife and conservation, in the problems arising from rapid metropolitan area growth and similar matters. In spite of this wide divergence of interest and allegiance one of the unanimous points of agreement in our discussions was that human health in the broader sense should be given primacy among the considerations which had to be taken into account in projecting future plans for federal leadership and participation in the environmental health field.

4. The Committee further agreed that prior approaches to the scientific and technical aspects of environmental health problems had been quite fragmentary in nature and that there was a need for a broadly integrated approach on the scientific side to undergird and back up the heavily categorical approach through the divisions of air and water pollution, occupational health, etc., traditional in the Public Health Service activity in environmetnal health. The Com- ··. mittee's proposal for development of such an integrated approach was the establishment of a high level environmental sciences group within the Public Health Service which has since emerged after many vicissitudes in the form of the Environmental Health Sciences Center now being developed in the Research Triangle in North Carolina.

The Committee's hope in proposing such a unit was not only that it would be free to carry out the basic mission related to research needed to undergird the existing somewhat fragmented categorical activities within the Public Health Service, but that it would also supply back-up services to the various categorical technical groups within the service.

The ability of such a Center to perform the latter functions is obviously diminished by its separate location in North Carolina away from the main body of U.S.P.H. environmental health activities in the Washington area. However, this is a decision that has been taken and, as such, is water over the dam.

5. Beyond the diminution in functional effectiveness just mentioned, there is a more serious matter relating to this Environmental Health Sciences Organization which comes from the rumored news of the impending reorganization of the U.S.P.H.S. in the February 1 Environmental Health Letter. This, for what the information from such a source may be worth, outlines a multi-bureau structure under which environmental health activities in the U.S.P.H.S. would be put under a Bureau of Disease Control and the new Environmental Health Sciences Center would come under a Bureau responsible for the National Institutes of Health and become another of such institutes.

6. In commenting on this reorganization the following quotation appears: "The greatest need in environmental health is for scientific information on the impact of contaminants on human health. This is essentially a research challenge, susceptible to organization and administrative methods which have proved successful in other health fields. The N.I.H. structure would provide the most appropriate and efficient setting for this environmental research program". The statement in the first sentence, though obvious to many today as it was not five years ago, is correct in substantial measure. This is still a great need in environmental health and will continue to be for some decades ahead. However, I and many of my colleagues involved in environmental health activities have grave doubt that such a research activity should be placed under the N.I.H. organizational structure as proposed in the statement. This is not to be construed as any reflection on the fine record of the Institutes in the medical research field under the policy guidance of the university medical groups and with cooperation from the private sector through the pharmaceutical industry. The achievements

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