The list of incurable diseases for which so-called "cures" cannot be sold, has been cut from 42 to 9.

The restriction against advertising a mere palliative as a cure has been removed.

Standards of strength for germicides and antiseptics have been eliminated.

There are no quality standards for food; there is no grade labeling. There are no minimum fines; fines have been reduced.

Protection against cumulative poisons, stimulant depressants, and sedatives has been removed.

There is a complete reversal of the original ethical stand on the quality of exports.

Weakening administrative changes have been made.

There is the shocking restriction of multiple seizures to those products only that are "imminently dangerous to health."

This very incomplete list of the weakening changes made before S. 5 passed the Senate will indicate the power of its opponents.

To date, the opponents of this bill have been the victors. Very skillfully they have drawn the teeth they feared. May we beg you now to listen to and heed those who are impersonally interested in this legislation, interested for the consumer's sake? May we earnestly request your committee, in considering this legislation, to study particularly the eliminations and amendments made to the early drafts of the Senate legislation and the sponsors of these eliminations and amendments, and may we hope that you will see fit to reinstate in your bill much of the original consumer protection once carried by the Senate draft? Specifically, we endorse and urge upon you the changes in S. 5 suggested to you at this time by the National Association of Home Economics and the League of Women Voters.

Mr. CHAPMAN. As I understand, that completes the list of those 12 ladies who are forming a sort of a joint program, does it not, Mrs. Bannerman?

The committee will be glad to recognize Mrs. Josephine Junkin Doggett.

STATEMENT OF MRS. JOSEPHINE JUNKIN DOGGETT, REPRESENTING THE GENERAL FEDERATION OF WOMEN'S CLUBS, WITH HEADQUARTERS AT 1734 N STREET, NW., WASHINGTON, D. C.

Mrs. DOGGETT. Mr. Chairman, I am Mrs. Josephine Junkin Doggett, representing the General Federation of Women's Clubs, with headquarters at 1734 N Street NW., this city.

I am here to represent the General Federation of Women's Clubs in favor of the principles of S. 5, the present administration bill, known as the "pure food, drugs, and cosmetics bill." Our organization comprises some 14,500 clubs, which are distributed throughout more than 3,000 counties in every State in the Union. Through delegates representing these clubs at a national convention, May 25, 1934, following some months of study by these clubs, the convention voted unanimously to endorse the general principle and the purpose of S. 2800. We feel that this present administration bill is the evolution of the original bill. We are particularly interested in this

proposed legislation because we feel it provides improved safeguards to the public health and a broadened scope of supervision. Perhaps you will be interested in the method by which we arrive at such endorsement, Mr. Chairman. Resolutions must be sent to rach member club at least 2 months before they are to be voted upon. It often happens, as it did in this case, that in January we present to our board of directors, the January preceding the convention, speakers both for and against issues. In January 1934, speakers on the new food and drug legislation were heard. Following that, we recommended to our clubs a study of the new pure food and drug legislation.

We also say that no member club, no minority expression of opinion in our member clubs is to be curtailed; that any minority opinion may be continued and the club may continue to work for that minority opinion, if, at the same time, it expresses the point of view of the majority of the organization.

Mr. CHAPMAN. Pardon me, Mrs. Doggett. Has the Federation of Women's Clubs changed its policy in that regard in recent years? Mrs. DOGGETT. Has it changed its policy?

Mr. CHAPMAN. Yes.

Mrs. DOGGETT. It has always been governed by a majority. This action was unanimous, for the purpose of the record.

Mr. CHAPMAN. Have the minority had that same privilege always that you say they have now?

Mrs. DOGGETT. We used to say, some 10 years ago, that the clubs should not, as clubs, work against the expressed opinion of the parent body, but that individuals might continue to, but now, for a number of years, it has been interpreted that clubs, as well as individuals, could continue to work for the minority point of view.

Mr. CHAPMAN. Then the national authorities of the Federation have ceased to dominate and dictate to the local clubs, as they did a few years ago, and now each of these 14,500 individual women's clubs has some right to self-expression?

Mrs. DOGGETT. I believe, Mr. Chairman, that you will agree with me that they have always had a right to self-expression. Delegates to the convention have had the privilege of being instructed by their clubs. They knew before they went to the convention the resolutions that were to be voted upon, and I believe that we do not say, when legislation is passed by the Congress it must be endorsed by each local community before it becomes a law. It is always the majority that governs, is it not?

Mr. CHAPMAN. Is it not a fact, though, that after the main body. the national body, decided that their will was binding on each local club, the local club could not express any adverse opinion or adopt any resolutions at variance with that to send to their Members of Congress, and instead of instructions coming from the individual clubs to the central body they went from the central body to the individual clubs?

Mrs. DOGGETT. We did not instruct those clubs. Our resolutions were only voted upon after they had been submitted to the member clubs.

Mr. CHAPMAN. I am glad to know that this great organization has reformed from that standpoint.

Mrs. DOGGETT. You do not believe in majority rule or rule of the majority?

Mr. CHAPMAN. I believe it should come up from the local clubs, instructing you, instead of from the central body to the local clubs. I do not think that they should be bound by any action of the national body, but that is beside the point, and I am just delighted to know that the situation is much better than it was a few years ago. Mrs. DOGGETT. Well, Mr. Chairman, you believe that we should not be bound by the laws of the United States unless we individually express our opinions on them?

Mr. CHAPMAN. You may proceed, Mrs. Doggett.

Mrs. DOGGETT. The history of the General Federation of Women's Clubs has been very closely associated with pure-food and drug legislation since early in the century, when we were very active supporters of the bill which became the present law, the so-called "Wiley Law." I do not believe that I expressed earlier that this was the unanimous endorsement of the convention, and I would like to put that in the record.

Mr. KENNEY. Let me understand about the minority you are talking about. Even though there is a majority vote in favor of a certain principle, the minority still has a right to keep up its fight until it can become a majority, if that is possible.

Mrs. DOGGETT. That is true, and we have a regulation which states that when we record the vote of the minority

Mr. KENNEY. How long has that been in effect?

Mrs. DOGGETT. The recording of the vote of the minority?

Mr. KENNEY. Yes.

Mrs. DOGGETT. It has been the policy for some time, but was voted by the convention at the last convention as the formal policy, but it has been in practice for some time.

Due to the size and character of our membership, around 2,000,000 women who are mainly homemakers, we feel that we are in an advantageous position to give you the point of view of the consuming public. Women are the primary purchasers of the type of merchandise dealt with in this bill, and we feel very strongly that means should be provided to enable them to judge more accurately the quality, character, and wholesomeness of the things they buy.

While in hearty accord with the principles embodied in the bill as drawn, we would suggest a few changes which, from our point of view, would strengthen its provisions and add to the public protection.

I will not go into great detail, because you have had these suggested amendments given to you already.

The first is section 401 (b): The General Federation believes that in the interest of the purchaser provision should be made to indicate on the label the nature and extent of the deviation from the official standards set up for drugs.

Section 711 (a), line 14, which deals with multiple seizures for misbranding, we believe that some phraseology should be put in there to provide for those goods which are a clear imposition on the public. You can use "grossly deceptive ", the amendment which has been suggested, but we are not giving you the phraseology. We want the protection.

I think adequate presentation of examples have been given you by Mr. Campbell, Mr. Forbes, and others who have appeared.

We oppose any idea to transfer authority from the Pure Food and Drug Administration to the Federal Trade Commission, because:

First, the Federal Trade Commission is dependent for scientific research on the Food and Drug Administration, and

Second, because the Food and Drug Administration is constituted to act for the consumer, whereas the emphasis of the Federal Trade Commission must be in the interest of fair-trade practices.

Mr. KENNEY. There would not be a transfer, would there?

Mrs. DOGGETT. There would not be what?

Mr. KENNEY. There would not be any transfer, because it is not now vested in the Food and Drug Administration.

Mrs. DOGGETT. I believe there has been a proposed transfer of regulations, has there not, of the carrying out of the regulations?

Mr. KENNEY. I think it is inaugurating an entirely new thing, is it not, so that it would not be a transfer? It would be vesting the jurisdiction not now existing in one or the other or both.

Mrs. DOGGETT. Well, we would like to have the jurisdiction rest with the Food and Drug Administration.

Mr. CHAPMAN. Mrs. Doggett, that would not interfere, would it, with the performance by the Federal Trade Commission of the functions now performed by it?

Mrs. DOGGETT. Not at all; in this bill it so stipulates.

Our third reason is that the Federal Trade Commission has not sufficient punitive authority, and protection to the public is only incidental. We want enforcement of the law in the hands of the Food and Drug Administration.

Mr. KENNEY. Now, this bill should give it all of that authority, could it not?

Mrs. DOGGETT. Yes; it could give it the authority, but I believe it is a very poor thing to do, as I understand it.

Mr. KENNEY. Do you object to us giving the Federal Trade Commission what you want to give the Agriculture Department?

Mrs. DOGGETT. Not at all, but I believe the Federal Trade Commission was established to supervise unfair trade practices, rather than to function in the interest of the consumer.

Mr. KENNEY. We are not going to establish a new jurisdiction here. You cannot compare this with the present jurisdiction of the Federal Trade Commission.

Mrs. DOGGETT. Would you change the whole authority, the whole purpose for which the Federal Trade Commission was set up?

Mr. KENNEY. We have to set up something new here, in either case, and whether what we set up will be given to the one or to the other remains with Congress.

Mrs. DOGGETT. We think the Food and Drug Administration has the scientific force to carry that out.

Mr. KENNEY. Yes; but you are criticising the limitations of the Federal Trade Commisison. Now, there are no limitations with respect to this bill, because we could remove any limitations there are and give them just as much power as we could give to the Food and Drug Administration.

Mrs. DOGGETT. Well, would you not have to set up, have a set-up back of that, to give them information?

Mr. KENNEY. You would not have to have any more set-up with them than you would with the Food and Drug Administration.

Mrs. DOGGETT. As I understand, the Food and Drug Administration would have all of the information upon which to base the work to be carried out.

Mr. KENNEY. Well, yes; they probably would get it in the first instance, but that would not retard the Federal Trade Commission which has a force now that investigates false advertising, and I understand that the Food and Drug Administration has no such staff, or a very limited staff.

Mrs. DOGGETT. Has that prevented false advertising?

Mr. KENNEY. Now you are asking me questions. I think it has, to a large extent, and I think it is just as effective as it would be under the Food and Drug Administration; but you are addressing questions to me now, and I am simply asking you. You are criticising the Commission because it has limited powers under some other law. I do not think that is pertinent to the discussion of this bill, where we are undertaking to grant new powers, either to one or the other or to both.

You may go ahead.

Mr. COLE. May I ask a question at that point?

Mr. CHAPMAN. Mr. Cole.

Mr. COLE. I understand you feel that the department of the Government which controls the contents of that can [exhibiting can] and the label on it has the scientific force necessary, and should also control the advertising of the same article?

Mrs. DOGGETT. I believe that the advertising statements have to be based on the investigation as to the contents of the can; yes, sir. Mr. COLE. The violation is in advertising that article, and would not be an unfair trade practice.

Mrs. DOGGETT. Not at all.

Mr. COLE. Even if it were untruthfully advertised. But you think the same department should deal with the labels and the contents? Mrs. DOGGETT. That is true; yes, sir.

Mr. CHAPMAN. Thank you.

The committee will be glad to hear from Miss Izora Scott, of the National Woman's Christian Temperance Union.

STATEMENT OF MISS IZORA SCOTT, NATIONAL WOMAN'S CHRISTIAN TEMPERANCE UNION, WASHINGTON, D. C.

Mr. CHAPMAN. Will you state your name and address, Miss Scott? Miss SCOTT. Izora Scott, 100 Maryland Avenue, representing the National Woman's Christian Temperance Union.

Mr. KENNEY. How many members?

Miss SCOTT. Well, it all depends upon the number that pays a dollar dues every year, from 300,000 to 400,000, 500,000, according to the depression.

Mr. COLE. Do you have more members since prohibition than you had before?

Miss SCOTT. We had as many new members last year as we have ever had in our history.