technical knowledge necessary for them to execute their responsibilities under the act and the program of their own agencies. Subsection (g) of section 2 empowers representatives of the Department of Health, Education, and Welfare, to inspect Federal property to determine control practices of the various agencies. The council believes such authority is essential if the Secretary is to present annually to the President and Congress a factual report on the status of the control program throughout the Federal Government. Responsibility for keeping the Secretary informed about pollution conditions and steps taken to remedy them is placed in the hands of each department head. In some cases, at least, the distance between unsafe practices at the local installation and the office of the agency head can be long, indeed. In dealing with Federal activities as widespread, numerous, and complex as these, it is necessary that inspection by another agency be authorized. Finally, the council is happy to endorse H.R. 7429, either on its own merits or as incorporated in any other bill of general application to eliminate air pollution. STATEMENT BY BENJAMIN SCHWARTZ, EXECUTIVE CONSULTANT OF NATIONAL FEDERATION OF INDEPENDENT SCRAP YARD DEALERS, INC. In studying S. 306-the Solid Waste Disposal Act of 1965-we respectfully note the following: The unwarranted confusion that has developed in the concepts of scrap processor, auto graveyard, garbage, and other forms of "solid waste," is a gratuitous denigration of more than 50 years of effort invested in raising the standards and the image of those engaged in the secondary raw materials industry, as "conservers of natural resources." We are dealing with an industry that collects, grades, prepares in merchantable form, and otherwise processes scrap iron and steel, nonferrous scrap metals, paperstock, cotton and woolen textiles, burlap, scrap rubber, and other secondary byproducts of obsolescence and manufacturing operations, as part of a continuous cycle of conserving for future generations primary ores and metallics, nature's plant fibers, the forests that supply pulp, and other virgin resources. The two important characteristics of the economics of the secondary raw materials industry, are the collection army at the base of the industry, and the function of the law of supply and demand, operating in a free market. The industry is composed essentially of independent and small business units who represent the last outpost of individual initiative, within a highly “captive” industry. The survival of the small and independent operator, and his share of the market, are threatened by the increasing concentration of economic power in the scrap business. Monopolistic trends in the industry, and the reciprocal and exclusive deals affecting the commodities, are raising the serious question whether there will be a place for the small or independent dealer in the future of the industry. In terms of a national emergency, the question is not whether the scrap will be around, but whether the human beings and the organization for the collection and processing of the scrap, with its unique ability and experience acquired over many years, will be there when it is needed. It is our position that scrap is charged with the "public interest," because it involves three national policies-national defense, conservation, and the preservation of small business. Unless the top policymakers in Washington, who represent and interpret the "public interest," include the secondary materials industry in their policy studies, the activity at lower administrative and nonpolicy-making levels of advisory committees, task forces, solid waste panels and other ad hoc inspirations (of which we have had many in our time), will cause the industry to fall between many stools, and will speeed up the disintegration of the industry's essential base of small and independent units, so vital to the economics of secondary raw materials. Fundamentally, the major problem is one of merchandising and marketing; of balancing the annual crop of secondary raw materials with the primary or virgin metallics, fibers, and other of nature's products; of removing the forces that tamper with the "free market" function. We respectfully question whether "solid waste" or "natural beauty" are proper forums for the study of the "free market." We question the advisability of spending any "solid waste" funds for any research projects affecting the equipment, the operations or the end products of the secondary raw materials industry, or setting up any experimental facilities that would duplicate the adequate facilities now in existence within the industry. We do not believe in the necessity of subsidy or other financial incentives, direct or indirect, for our industry; nor do we have any projects to suggest, because of the generous appropriations which Congress may have made in its wisdom in the name of research or "natural beauty." We respectfully urge an amendment to S. 306 (or a clarification of the definition of "solid waste" contained therein), exempting the services and the operations of the secondary raw materials industry from its scope. Hon. OREN HARRIS, [Telegram] PHILADELPHIA, PA., June 29, 1965. Chairman, Committee on Interstate and Foreign Commerce, On behalf of the National League of Cities, representing over 13,000 municipalities, and as mayor of Philadelphia, one of the largest cities in the country, located in the heart of a congested, rapidly expanding urban area, I am deeply concerned about the potential health hazards attributable to improper disposal of solid wastes. Present practices and knowledge are inadequate to manage this growing source of land, air, and water pollution. The need for research in refuse collection and disposal methods designed to prevent public health incidents is immediate. Since the problem transcends local and State boundaries and is the concern of three-fourths of the population of the United States, I believe it is a Federal as well as a local problem and therefore I strongly urge that you and your committee give favorable consideration to the immediate passage of bills H.R. 4854, S. 306, and other related bills. JAMES H. J. TATE, Mayor, City of Philadelphia. Hon. OREN HARRIS, [Telegram] DENVER, COLO. Chairman, House Committee on Interstate and Foreign Commerce, Re S. 306, title II, solid waste disposal, the National Association of Sanitarians, 1550 Lincoln Street, Denver, Colo., the second largest public health organization in the United States, is a door to safety. But we would appreciate the addition of the following: State Governors should have authority to determine where the funds should be used, since all States do not have an air control organization. Federal money is needed to help States in getting solid waste disposal programs initiated, and a minimum of $2 million should be appropriated to assist in solving the waste disposal problem. If we can be of any assistance, please feel free to call this office, 303-222-4456. We will be grateful for your consideration of the above. NICHOLAS POHLIT, Executive Director, National Association of Sanitarians. Hon. OREN HARRIS, [Telegram] BOSTON, MASS., July 2, 1965. Chairman of Interstate and Foreign Commerce Committee, Massachusetts Department of Public Health strongly urges passage of title II of S. 306. Passage of this act will provide sorely needed research, technical, and financial assistance in planning and conducting solid waste disposal program. Disposal of solid wastes is becoming increasingly difficult and expensive. Development of sanitary and economical method of solid waste disposal must be encouraged since space for disposal of these wastes by present means is rapidly disappearing in Massachusetts. STATE HOUSE, BOSTON, MASS. ALFRED L. FRECHETTE, M.D., Massachusetts Commissioner of Public Health. [Telegram] SUBCOMMITTEE ON PUBLIC HEALTH AND WELFARE, NEW YORK, N.Y., July 2, 1965. OF THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE, House of Representatives, Washington, D.C. (Attention of Hon. Oren Harris, Chairman): Wish to express deep interest in the research on solid waste disposal that is contemplated in S. 306. Our committee has a membership of 272 including the foremost designers of municipal, industrial, and commercial incinerators. We are active in collecting, organizing, and freely disseminating technical information on incineration. The control of air and water pollution are important topics of study. Frequent meetings are held for these purposes, with liaison and interchange with other professional and trade associations. A national incinerator conference of 600 persons was held in May 1964, to hear engineering papers on various phases of the subject. A second national conference is scheduled for May 1966. We have frequently discussed the obvious lack of sufficient published or private information on all aspects of incineration, including, among others, refuse analyses and quantities, combustion, prevention of fly-ash emissions, equipment design and maintenance, prevention of water pollution by plant effluent and residue. It is our conclusion that the necessary research will not be supported sufficiently by municipalities or others, but that a Federal research program under Public Health Service is necessary. We are favorably impressed with the publications that have resulted from the Public Health Service programs on late disposal and air pollution control. As further research is conducted and published the incinerator profession and industry will be better to design plants to cope with the mounting refuse problem in an economical manner and in the best public interest. JUNIUS W. STEPHENSON, Chairman, Incinerator Committee, DEPARTMENT OF THE INTERIOR, OFFICE OF THE SECRETARY, Washington, D.C., July 7, 1965. Hon. OREN HARRIS, Chairman, Committee on Interstate and Foreign Commerce, House of Representatives, Washington, D.C. DEAR MR. HARRIS: Your letter of June 29, 1965, asked if we construe the provisions of the Senate-passed bill S. 306 with the amendments suggested by the Department of Health, Education, and Welfare in their report of June 10, 1965, to include authority to restore abandoned strip mines. Your letter refers to section 203 (a)(3) of the HEW draft bill. We think the reference was probably intended to be to section 204 (a) and (b) (3). This section when read in conjunction with the definition of the term "Secretary" in section 203 (a) directs the Department of the Interior to encourage, cooperate with, and give financial, technical, and other aid to public and private agencies and institutions, and individuals in the conduct of research, investigations, experiments, training, demonstrations, surveys, and studies relating to the operation and financing of solid waste disposal programs, the development and use of new and better methods of disposal, and the reduction of the amount of waste and unsalvagable waste materials. The Secretary is also authorized to carry out these activities directly. Thus, the bill enables this Department to carry out a comprehensive program designed to meet the problems of solid waste disposal resulting from the extraction, processing, or utilization of minerals or fossil fuels where such activities are or could be controlled within the operating or inactive facility or facilities, such as the plant, a coal mine (active or inactive), or strip mine (active or inactive). It includes authority to make grants to public or private agencies and institutions and to individuals for, among other things, demonstration projects. One type of demonstration project relates to the disposal of solid wastes, which could include restoration work at abandoned or active strip or surface mines. This is, of course, only one of many types of demonstration projects. Surface or strip mining began in Illinois as early as 1866. It is a surface operation which removes or strips the overburden of soil and rock to expose the subsurface minerals. This type of mining involves problems of solid waste disposal, soil erosion, and water pollution. Either because of inadequate local laws or lack of enforcement thereof, little work has been done by the owners of these areas to restore the land for useful purposes. The removal or disposal of the huge pile of overburden is one of the major cost items in the extraction of some minerals from strip or surface mines. In addition, these piles of overburden pose serious problems of disposal. One proposal is to return the overburden to the excavation and recontour the area and add plantings. S. 306 with the Health, Education, and Welfare amendments will aid us in finding, on a demonstration basis, economic and feasible means for disposing of this overburden and removing this unsightly condition from the landscape. These demonstration projects will also aid us in our comprehensive and longrange study of reclaiming and rehabilitating strip and surface mine areas in the United States which we are now conducting pursuant to the recently enacted Appalachian Regional Development Act of 1965 (79 Stat. 5). Insofar as these demonstration projects are carried out in other than publicly owned lands, we will take such steps as may be necessary to prevent anyone from receiving windfall benefits from the projects. We appreciate this opportunity to further comment on the bill. Hon. OREN HARRIS, STEWART L. UDALL, Secretary of the Interior. DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE, Chairman, Committee on Interstate and Foreign Commerce, July 8, 1965. DEAR MR. CHAIRMAN: This is in response to your letter of June 29, 1965, requesting clarification of the definition of the term "solid waste" contained in the draft Solid Waste Act recommended by the administration. The definition contained in the draft bill is: "The term 'solid waste' means garbage, refuse, and other discarded solid materials, including solid waste materials resulting from industrial, commercial, and agricultural operations, and from community activities." The American Public Works Association has classified wastes into solids, liquids, and gases. "The gases are principally industrial fumes and smoke; the liquids consist mainly of sewage and the fluid part of industrial waste; the solids are classed as refuse." "Municipal Refuse Disposal," American Public Works Association, 1961. Refuse can be classified in different ways, i.e., according to point of origin— domestic, industrial, agricultural, or commercial; or, as preferred by American Public Works Association, according to kinds of materials "garbage, rubbish, ashes, street refuse, dead animals, abandoned automobiles, industrial wastes, demolition wastes, construction wastes, sewage solids, and hazardous and special wastes.' Clearly, it does not include dissolved solids carried in liquid form through sewers and watercourses, although it is to be noted that improper disposal of solid wastes may contribute dissolved substances to ground and surface waters, by leaching. In the definition of "solid waste disposal" in our amendment, to avoid program duplication, we recommended that organic solids in untreated domestic sewage be excluded from the purview of this bill, as the Federal Water Pollution Control Act deals with this factor. Similarly, that act, in establishing a pattern of water pollution control activity, deals with other significant pollutants in water resources, such as silt, dissolved salts, suspended solids in municipal and industrial sewage effluents, and other common water pollutants. This distinction makes clear that salt pollution in irrigation return flows, a major contributor to water pollution, is within the scope of that act and is not included within a solid waste disposal program. It is the position of the Department of Health, Education, and Welfare that solid waste is appropriately described by the definition in our proposed amendment to the bill. However, it would be appropriate to further explain this definition by including these comments in the legislative history of S. 306. Sincerely, WILBUR J. COHEN, Secretary. Hon. OREN HARRIS, AMERICAN PETROLEUM INSTITUTE, Chairman, House Committee on Interstate and Foreign Commerce, House of Representatives, Washington, D.C. DEAR MR. CHAIRMAN: Attached is a copy of a letter from the chairman of the American Petroleum Institute's central committee on medicine and health to Dr. John L. Buckley, of the Office of Science and Technology, Executive Office of the President. This letter was delivered yesterday to Dr. Buckley in compliance with the request he had made earlier to the American Petroleum Institute. The letter proposes, we believe, a knowledgeable and workable system to prevent health-damaging air pollution. We think you will find it to be of interest. Dr. JOHN L. BUCKLEY, Executive Office of the President, FRANK N. IKARD. STANDARD OIL CO. (INDIANA), Office of Science and Technology, Washington, D.C. DEAR DR. BUCKLEY: At our meeting on June 11, you offered me the opportunity to present, at a later date, our viewpoint on an acceptable health standard for sulfur oxides in ambient air. I am pleased to present the following to you at this time on behalf of physicians of the petroleum industry and the Coordinating Committee on Air and Water Conservation of the American Petroleum Institute. Recognizing that an air quality standard by itself will not control air pollution, we are including discussion of other aspects necessary to effective solution of the problem. We suggest for your consideration the outline of a realistic control system that incorporates guidelines to communities, both for air quality and for their action. When properly utilized, we believe it is a system capable of preventing health-damaging air pollution episodes from occurring in the future in American cities. The suggestions represent the best thoughts of petroleum industry medical and technical people with a broad range of experience in this field. In addition, a number of these people, including myself, had the opportunity of attending the recent Gordon conference on sulfur oxides and related compounds. There, we were able to explore with many of the world's experts the latest findings in this complex field. I believe, therefore, that the proposal which we are making is as faithful a reflection of present knowledge as can be obtained. Available information does not indicate that sulfur dioxide by itself is causing any adverse health effects in our population. However, elevated concentrations of particulates and sulfur oxides in the air produce a combination capable of pronounced health effects. Also, we have carefully studied all available data on air pollution episodes which were associated with illness among humans and find that experience agrees with the above. In none of these health-affecting episodes for which atmospheric pollutant concentrations were measured was there an increase in sulfur dioxide which was not accompanied by a significant increase in particulates. On the other hand, instances are on record where SO2 levels were high, but particulate levels low, and local illness and death rates remained within their normal range. A logical explanation for these observations exists. Inhaled alone, most sulfur dioxide is removed by the mouth, nose, and throat, thereby preventing all but a small fraction from gaining entrance into the lower respiratory tract. But when substantial particulate matter is present in ambient air along with sulfur dioxide, the sulfur dioxide may be adsorbed onto the particles and may then be carried deeper into the respiratory tract where any irritation it produces would be of much greater significance. Thus, we believe any realistic proposal on the acceptable levels of air contaminants ties these two together. Furthermore, any practical control system must deal with sulfur oxides (not just sulfur dioxide by itself) in combination with particulate matter. Every recorded air pollution episode involving more than a limited area has involved air stagnation brought about by an atmospheric inversion; a high layer of warm air has virtually formed a lid or cover over the community and |