comes from various Government sources, and is earmarked for specific projects. About $70,000 a year, or between 18 and 20 percent of the budget, comes from industry. This money supports the Food Protection Committee and in large measure the overall operations of the Board itself.

The Board consists of members who serve without salary, a staff of three to four professionals, and supporting personnel. The Board meets three to four times a year and transportation and expenses of Board members are paid for by the Board. The meetings are of 1 to 2 days' duration and usually include a joint meeting with representatives of the liaison panels.

The various committees and subcommittees are also supported with travel funds when the funds are available. The virtual lack of assured support for the Board makes it almost impossible for there to be any latitude or significant innovation. Many committees are unable to perform their work for lack of support.

This absence of flexible funding was of significant concern to me during my tenure with the Board. My larger concern, however, has been the question of bias and conflict of interest because of the role that industry has played. Although Board members deny that this is an issue and the staff tries to be impervious to this criticism, many of the people who deal with and/or listen to the Board will be concerned about the possibility of bias as long as the present funding situation exists.

Although the Board considers itself the leading nutrition agency in the country, it actually appears to have little visibility outside of the immediate nutrition community. Except for some Government agencies, the Board is rarely consulted on nutritional matters by large professional organizations and Government agencies which are increasingly forming their own internal nutritional coordinating groups. For example, the General Accounting Office recently researched and published "What Foods Should Americans Eat?" on April 30, 1980.

Having discussed some of my personal observations, I would now like to address some of the more general concerns voiced about the Food and Nutrition Board. I will try to keep this within the perspective of my 3 years of service.

The Board tends to perform the routine tasks it has been doing for years quite well. However, there is little innovation. I realize that much of this is undoubtedly due to economic restrictions, but I believe it can also be attributed to the composition of the Board itself and the staff narrowly representing basic nutritional sciences.

I found a total lack of long-range planning or discussion of future nutrition problems that might be of concern to the scientific community and the people of the United States. There was essentially no discussion of how and/or whether the Board would deal with these.

At the last meeting I attended as a member, a retreat was held in order to begin some longer range planning and to define the functions and problems faced by the Board. I considered this a valiant and very hopeful attempt and was excited by the prospects which this type of dialog held. As an example, at this meeting a decision was made to add social scientists to the Board. I have no idea what the impact of this has been on the Board in the intervening years.

I found that the Board had an almost total lack of concern with nutrition policy issues. In fact, I wrote a memo to this effect which is attached to this testimony as appendix A. I firmly believe that although the main function of the Food and Nutrition Board may be to investigate and evaluate scientific matters in the areas of food and nutrition, it should also analyze the policy implications of these findings and facts and make these available to our policymakers.

I have been concerned with the fragmentation, lack of communication, and competition within the Academy in the areas of food and nutrition. In some cases this has led to incomplete analyses of various important issues and in others important issues have fallen between the cracks and not been considered at all.

I agree wholeheartedly with parts of the report of the visiting committee to the Food and Nutrition Board submitted to the Assembly of Life Sciences of the National Research Council, National Academy of Sciences, dated September 26, 1977.

This report is included as appendix B. I would like to quote from page 6 of this report:

It is clear that this Nation urgently needs effective leadership in responding to a complex set of problems and challenges that go far beyond the provision of an adequate food supply and the determination of the composition of a satisfactory diet based on conventional foods. These problems-many of them which are multidisciplinary—include, but are not limited to, behavioral patterns and selection of appropriate diets; new food consumption patterns, new marketing patterns and practices; palatability; olfaction and taste preference; education of the general population in the exercise of individual responsibility; interpretation of nutritional needs for Congress, regulatory agencies, and the public; economics of food; and development of a national food and nutrition policy. Particular attention should be given to the changing nutritional wants and needs of the elderly and ill, and those served by public programs and institutions.

Although this is a long list of problems that must be addressed by food and nutrition scientists, it is not even comprehensive. As presently constituted and funded, I do not think that the Food and Nutrition Board is capable of responding to these new demands and new leadership roles without a marked restructuring of the Board.

In view of the need for a multidisciplinary approach, the visiting committee and others had recommended a broadening of the backgrounds and characteristics of Board membership. I, as well as others, would even urge consumer representation.

At present I do not wish to enter into an argument on how best to restructure the Board, but I believe it is important to restructure the means of addressing the food and nutrition problems of our Nation. If the Acadamy is to take a leading role in this problem, then it must act in a forthright and forceful manner to do so.

It is clear that on many issues various Government agencies are bypassing the Academy and the Food and Nutrition Board. The reasons for this have been alluded to rather clearly in the report previously mentioned.

In the process of the restructuring the Academy must also reorganize the food and nutrition area to be able to respond rapidly to significant questions which arise either within the scientific or consumer communities. The slowness of response, which often has been extremely important for proper scientific deliberation, must at times be sacrificed in order to aid the policymakers even if the degree of cer

tainty that characterizes pure scientific investigation is not yet available and immediate.

In conclusion, I believe that certain minimum changes are essential if the Board is to regain the prestige and leadership that it once had. Among my recommendations are:

First: The development of a clearcut mandate for its operation.

Second: I recommend a decrease in the secrecy with which the Board, as well as the Academy, operates. This applies both to the selection of its membership and its committees and greater openness in all aspects of its operation. These alone, however, will be insufficient to help solve the emerging food and nutrition scientific policy issues facing the United States. The Academy itself must also address these questions, but more important still organize the food and nutrition activities in such a way that not only is there coordination but more important a central area of planning, control, and implementation.

Third: I recommend a broadening of the expertise of its members to be better able to address the complex issues which nutrition now faces and will increasingly face in the future.

Fourth: I think a firm basis of nonindustry financial support must be established to provide the Board with some flexibility and to avoid the suspicions and possibility of bias.

Fifth: I urge the ability to respond rapidly to food and nutrition issues that are of public concern-that is, that are matters of public policy.

These recommendations alone, however, will be insufficient to help solve the emerging food and nutrition scientific policy issues facing the United States. The Academy itself must also address these questions but, more important still, must organize the food and nutrition activities in such a way that not only is there coordination but, more important, a central area of planning, control, and implementation.

Whether any of this can be done within the present framework of the Food and Nutrition Board is obviously an open question. However, I believe the Academy must see to it that as a minimum the above conditions are met and that full support and commitment is given to the areas of food and nutrition.

President Handler stated this well when he referred to the reorganization of the National Research Council that took place a number of years ago:

We have placed upon the NRC the burden of foresight, the responsibility for scanning the horizon to identify problems as early as possible, to participate in the analysis, and to make such recommendations as appear appropriate in the light of that analysis.

Carrying forth that mandate will certainly eliminate many problems in the areas of food and nutrition that have plagued both the Board and the Academy.

The question which I have not addressed and which must be considered is the future role that the Food and Nutrition Board and the Academy are to play in the area of food and nutrition. Whether or not the Food and Nutrition Board and/or the Academy are the proper agencies to assume a major role in food and nutrition problems and to make recommendations for policy is an issue that should be reopened after 40 years of the Board's existence.

The possibility that other mechanisms may be more effective and less subject to potential bias should be examined. It must be made clear to the Board that it is not a policymaking body. All of the testimony I have given has been predicated on the assumption that the Food and Nutrition Board or some similar body of the Academy would continue to function.

Although the Academy and/or the Food and Nutrition Board are only quasi-public organizations, since so much in the way of public funds support the organizations, methods of assuring accountability and openness must be developed if a fruitful relationship between them and the public is to remain and develop.

[App. A follows. App. B is held in the subcommittee file.]

APPENDIX A

REVIEW OF THE ROLE OF THE FOOD AND NUTRITION BOARD IN 1976

I. Is the Food and Nutrition Board the highest official authority on questions of scientific nutrition of humans in the U.S. today? If so, how should it play this role?

1. Should it respond only to questions of scientific nutrition originating within the scientific community or by members of the Food and Nutrition Board and/or its liaison committees?

2. Should the Food and Nutrition Board be concerned with the application and development of food and nutrition problems to public policy in the U.S.? If so, how is this to be accomplished?

3. Should the Food and Nutrition Board be the originator and attempt to answer questions of public policy regarding food and nutrition in the U.S. today?

4. How can the Food and Nutrition Board be most responsive to the scientific, industrial and consumer communities in areas of public policy regarding food and nutrition?

II. What is the role of the Food and Nutrition Board in relation to governmental agencies dealing with food and nutrition policy?

1. Should all food and nutrition policy questions, whether of a scientific or public policy nature, be scrutinized and if possible approved by the Food and Nutrition Board before entering the public domain? In particular, should agencies such as NIH, FDA, FTC, etc. consult with the Food and Nutrition Board before making any public announcements or issuing any directives in the area of food and nutrition policy?

2. If it is agreed that such is desirable, what mechanisms might be devised to assure that such would take place?

III. How can the Food and Nutrition Board accelerate its responses to questions either originating within the Board, the scientific community, government agencies or the private sector?

One of the criticisms which has been aimed at the Food and Nutrition Board is the long delays in obtaining answers to questions and reviews of materials submitted to it. Many of these delays appear to be caused by actions of the Board itself, but also, much of the delay is caused by the extensive review process within the Academy. Should this process be accelerated and, if so, by what mechanisms, both within the Board itself and the Academy?

Mr. RICHMOND. Thank you, Dr. Margen.
Our next witness is Mr. James Turner.

STATEMENT OF JAMES TURNER, ESQ., CHAIRMAN, COUNCIL OF CONSUMER LIAISON PANEL, FOOD AND NUTRITION BOARD

Mr. TURNER. I have a short statement to read and have submitted some documents for the record.

Mr. RICHMOND. All of your documents will be included in the final record, Mr. Turner.

Mr. TURNER. My name is James Turner. I am a consumer interest attorney with the firm of Swanken and Turner in Washington, D.C. I currently serve as chairman of the Consumer Liaison Panel of the Food and Nutrition Board.

The authors of the recent Food and Nutrition Board report, "Toward Healthful Diets," hope to "reduce the confusion in the mind of the public that has resulted from many conflicting nutrition recommendations." They have failed in this effort.

This failure can be traced directly to weaknesses in the Board's organization and procedures. From the time that the Consumer Liaison Panel was invited into existence by the Board in 1974 it has repeatedly urged the Board to broaden its expertise and modernize its producers. It has also warned that failure to follow these recommendations would eventually lead to an increased national confusion about nutrition and undermine the credibility not only of the Board, in particular, but of nutrition science in general.

"Toward Healthful Diets" is the most recent example of how the Board has allowed its prestige to diminish and confusion about food issues to multiply. The report contradicts recommendations to the public by 20 international expert committees, the Surgeon General of the United States, and the Departments of Agriculture and Health and Human Services to eat less saturated fat and cholesterol in order to reduce the risk of heart disease.

The Board takes this policy position without the benefit of new scientific information, without recourse to a broad base of scientific review, and without utilization of the range of scientific expertise which should hopefully be brought to bear on a policy issue of this magnitude.

Instead, a professionally relatively narrow group of scientists has chosen to wrap their previously well-known personal positions on fat and cholesterol inside the mantle of the National Academy of Sciences. This report and its result are the culmination of a long struggle on the part of some members of the Board to undercut the efforts to develop a system of national dietary guidelines. It is a struggle which the Consumer Liaison Panel has criticized from its inception.

In February 1978 the Consumer Liaison Panel asked the Department of Agriculture to refrain from funding the Board's effort to evaluate proposed dietary goals unless provisions were made for the participation of a wide range of scientific disciplines, input from interested consumer groups, and provisions for minority reports in the evaluation. These provisions were not made part of the effort and the Department withheld the funds.

The Consumer Liaison Panel still believes strongly that all Board actions should be carried out with the processes which we recommended and believe that the failure of the Board to adopt them will lead to a continued confusion and decline of prestige and credibility of the Nation's food scientists.

At the time of its creation during the Second World War the Board made significant contributions to the nutritional well being of the American public through its role as advisor on national food policy and such matters as fortifying bread and establishing the recommended dietary allowances. In the last decade, however, the prestige of the Board has slipped.