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23 Food Drug Cosm. L.J. 260 (1968)
A Reasoned Approach to Regulation Based on Toxicologic Considerations

handle is hein.journals/foodlj23 and id is 288 raw text is: A Reasoned Approach
to Regulation Based
on Toxicologic Considerations
By JOHN P. FRAWLEY
The Following Article Was Presented at the National Con-
ference on Indirect Food Additives Held in Washington, D. C.,
Tuesday, February 13, 1968. r. Frawley Is Chief Toxi-
cologist for Hercules, Incorporated, Wilmington, Delaware.
A LMOST 2400 YEARS AGO, one of the greatest philosophers of
our culture, Plato, advised the rulers of ancient Greece: Noth-
ing is more unworthy of a wise man,, or ought to trouble him more,
than to have allowed more time for trifling and useless things, than
they deserved.
I do not pretend to be a wise man, but I am troubled and the
majority of the toxicology profession is troubled because we ;pend, so
much time on trifling and useless things. In no other area of environ-
mental health have we invested so much time and effort in unprofit-
able research, as we have on indirect food additives.
I think the very fact that this National Conference on Indirect
Food Additives is being held constitutes a recognition by government
that our priorities should be re-evaluated. I also think that this Con-
ference has been called because the Food and Drug Administration
(FDA) sincerely wishes our opinions and advice on how we can
protect public health in a more efficient manner than with our current
regulatory procedures on indirect additives. If my assumption is
correct, we have the unprecedented opportunity to offer our sugges-
tions and the responsibility to propose specific constructive mech-
anisms to improve our system.
I think it is imperative in any discussion of environmental health
to put the specific subject in perspective. Our environment is com-
posed completely of chemicals, most of which are of natural origin

FOOD DRUG COSMETIC LAW JOURNAL-MAY, 1968

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