I would like to say, Mr. Chairman, that we resolved this questionor at least substantially resolved it-respecting prescription drugs by establishing standards which require animal tests, human tests, and toxicity tests. These tests are presumably adequate to demonstrate the effect of the particular compound on the target organism as well as any possible side effects.

The parallel is similar, if not identical, between prescription drugs and the introduction of pesticides into the environment. As we introduce pesticides and herbicides into the environment we are affecting all living creatures that live in that environment, with consequences that have not been studied and cannot be predicted. It has been well known for quite sometime that DDT has serious effects on birds, on marine creatures, and possibly on human beings. Though we have had more than a decade of experience with DDT, finally yesterday Mr. Ruckelshaus set a deadline of December of this year for eliminating the use of DDT in this country except for a few limited crops and for public health purposes.

On May 30, 1972, the Senate cast an assent, in a 79 to 0 vote, with this subcommittee's position that adequate information must be accumulated and evaluated about the potential dangers of new chemicals before they are introduceed into the marketplace.

If it is agreed that this standard of technological assessment, or commonsense applied at a higher level, is now in order to develop the controls necessary to safely introduce new chemicals into our environment, how much more important is it to exercise a higher degree of care and control over those chemicals already pervasive in commerce and which have shown themselves to be extremely dangerous?

On March 7, 1972, Senator Hart and I introduced a package of 11 amendments to the House-approved version of H.R. 10729. The essential features of two of the amendments dealing with indemnities and with the criteria for general and restricted use were accepted by the Agriculture Committee.

It is important that any bill to reform pesticide regulation, which is reported to the full Senate, contain provisions for informed public decisionmaking on pesticides before the public health, the environment, or the commerce of this Nation are threatened or actually injured.

I am confident that H.R. 10729 and the remainder of the amendments which Senator Hart and I have introduced will receive thorough consideration and appropriate attention in this committee.

Particular attention is deserved by several of these amendments. Amendment No. 1012 would expressly provide that the social costs and social benefits will be considered in registering a pesticide. Amendment No. 1003 and amendment No. 1011 would allow citizens to have access to information at an appropriate time to participate in the administrative process, while also giving the public the right to participate in the enforcement proceedings.

Amendment No. 1007 seeks to insure a degree of impartiality in the makeup of any advisory committee of the National Acedamy of Sciences to which a scientific question may be referred. And amendment No. 1004 is important in that it would prevent needless duplication of test data and the restriction of competition in the pesticides

market.

All of these features deserve inclusion in any bill which professes to modernize and reform Federal pesticides regulations.

Instead of setting up mechanisms to search for the hard information and proof about pesticides, we have chosen to wait for evidence to force itself upon our consciences. And that is what we have done. We have been content to wait. And we have sat by and watched as each tragic step has unfolded.

Unfortunately, the dangers of highly toxic pesticides must still be proven in literal human terms. Only then is action taken to institute the appropriate preventive informational and control techniques.

It appears now that another such tragic incident is presently being documented in Iraq where an insidious epidemic of mercury poisoning has occurred. According to Dr. Thomas Clarkson and other University of Rochester scientists studying mercury toxicity under a June 1971 grant from the National Science Foundation in cooperation with the Food and Drug Administration, Iraq is suffering a severe outbreak of mercury poisoning, and the full effects of this episode may not be realized for generations.

I might say that in our investigation of this situation, and in discussing it with those who have been there accumulating information, this mercury poisoning catastrophe in Iraq is far greater than the tragedy in Minamata, Japan, where many people were poisoned and many more died.

The incident in Japan was several years ago, as you know, but just recently a substantial article was run on it in Life magazine.

The first cases of mercury poisoning were recorded by Iraqi officials on December 27, 1971, when 50 cases were officially recognized. By January, Iraqi officials in the Ministry of Health were recording 400 hospital admissions each day. All of the official cases occurred outside the urban areas of this country of 10 million people and involved peasant farm families, who had taken mercury-treated grains and utilized them to make bread instead of sowing them as seed.

Although official diplomatic relations between the United States and Iraq are severed, an invitation was extended in January of this year by scientists at the University of Bahgdad to Dr. Clarkson and the team of University of Rochester scientists working on mercury poisoning.

With the understanding, support, and essential cooperation of the National Science Foundation, Dr. Clarkson assembled the necessary men and equipment and affirmatively responded to the formal request for his assistance in February of this year.

The official Iraqi figures for this outbreak record 450 deaths and 6,000 hospital admissions.

However, it is felt that these figures could be multiplied by 10, which would bring you up to 60,000 mercury poisonings in that country and up to 4,000 deaths. Unofficial sources now report that 60,000 peasants may have ingested enough mercury to exhibit signs of damage. Actual deaths may eventually approach 1,000.

Mercury poisonings have occurred in the past several years at several points throughout the world, most notably in Minamata, Japan, in the State of New Mexico, and twice before in Iraq in 1956 and in 1960 when 350 people were severely poisoned and 36 deaths recorded.

But never before have the outbreaks been so large. In Minamata, Japan, where the largest known previous mercury poisoning occurred, 181 victims have been officially designated as sick and they have 52 listed deaths in the 20-year history of that disaster.

So you can see the comparative dimensions of these two tragedies. Mercury poisoning is irreversible and produces brain and nerve damage that can result in death, blindness, and loss of control of muscle function. As the Minamata incident has revealed, the results may be delayed and may not show up in a victim for months, or even years.

The more devastating effect of mercury poisoning, however, comes not from the neurological damage and destruction of brain cells, but from the teratogenic effects-birth defects suffered by the growing fetus while it is still in a mother's womb.

Even more insidious in its impact, since the damage may not surface for three, four, or five generations, is the effect of mercury upon chromosomal material. This is a change in the genetic code which can produce structural damage to any system, or any part of the body in some future generation.

The June 2, 1972 issue of Life magazine graphically showed the pathetic result of teratogenic damage to a fetus in a Minamata mother's womb. Life also reports in the same article that otherwise healthy women in Minamata are fearful of producing deformed children some 20 years after the first signs of mercury poisoning appeared.

Even if extrapolations on the number of Iraqi's who have been exposed sufficiently to the mercury poisoning to suffer damage cannot be definitively proven at this point, the number of official cases of deaths and hospital admissions, and a comparison with the Minamata experience, should raise great concern for the possible secondary and longer range results to children born of exposed mothers. The possibility of genetic damage must be considered.

In a country where the unofficial birth rate is 40 per thousand population each year, and where there is the ability of mothers to pass on a significant level of mercury to children through mother's milk, this concern must be taken seriously. The damage to present and future children may far outweigh the immediate effects on adults and be the basis for a major public health problem in Iraq for years to come.

In addition to the devastating effects of the poison on the country's human population, there has been an incalculable impact upon Iraq's aquatic, bird, and rodent population ecosystem. The relationship between the cats and birds that ate the rodents and the bugs that ate the grain that fed the population has been disrupted.

This tragedy is the result of improper use of wheat and barley seeds which were imported by the Iraqi Government late in 1971, and, at the Government's direction, coated with an alkyl mercury fungicide.

The exact origin of the grain involved in the Iraqi outbreak is not definitely clear. Treated grain came to Iraq in late September and October of last year in a shipment of 14,000 tons of barley and 63,000 tons of wheat, and in another shipment of 14,000 tons of wheat. While the barley is known to be of U.S. origin, there is some dispute as to whether the wheat was Canadian, American, or Mexican grown and in which country it was treated with the alkyl mercury fungicide.

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The barley and 63,000 tons of wheat were part of a trade between the Iraq Government and Cargill, Inc., of Minneapolis, Minn., or one of its international subsidiaries and trading corporations, such as the Tradex Corp. A Cargill representative was reported to be on the docks when the shipments arrived. The other shipment of 14,000 tons of wheat came from other sources and is thought to have been involved in a dispute at the border which delayed its entry into Iraq.

I emphasize that the Iraqi Government requested that the grain be treated with the fungicide. The grain was dyed red, and the language explaining the dangers was in either Spanish or English, neither of which languages the Iraqi peasants read. Many of them are illiterate in their own language.

So far, no one has indicated that the alkyl mercury fungicides used to coat the grain were of other than U.S. origin.

With the grain arriving in Iraq late in the summer after a devastating drought affecting crop harvest, it is believed that distribution to the farmers occurred too late for total use in planting. However, the large bird kills in the northern part of the country would indicate that some was used in sowing.

Most of the treated barley seed is believed to have been fed to the peasants' sheep and cattle. When the animals appeared to show no immediate effects, the peasants are thought to have begun to convert the remaining treated wheat in their possession into flour, and thus into homemade bread which is the staple of their diet.

With the bread came the approximately 6.7 parts per million of highly toxic alkyl mercury fungicide that coated the wheat seeds. With an average ingestion of three loaves of bread per day and with each loaf containing about 1.2 milligrams of mercury, each exposed individual would be ingesting about 3.6 milligrams each day of mercury.

The Swedish and Japanese literature on the subject indicate the appearance of the first symptoms of mercury poisoning when the body burden reaches the 30 milligram level. Other scientists look for the first signs of damage at the 100 milligram level.

Using both thresholds, it can be seen that with an average ingestion of three loaves of contaminated bread per day, it would not take an unusually long period of ingestion to build up a body burden of mercury sufficient to produce symptoms of serious damage.

With the peak of the admissions occurring in January, ingestion of contaminated bread could have occurred over a 6-month period from October 1971 to March of this year with the peak consumption occurring at the end of 1971.

If the flour eaten in Iraq had contained six parts per million of mercury, 1.000 tons of wheat would be sufficient to poison 60,000 people. Of the 80,000 tons of treated wheat known to have been sent to Iraq, the Government has confiscated and recovered 5,000 tons. When it is possible to seriously poison 60.000 Iraqis with 1,000 tons of wheat treated with alkyl mercury fungicides, and there are 75,000 tons of treated wheat which are still unaccounted for, there is cause for substantial concern. Whatever assistance may be the most appropriate cannot be denied in this situation.

It is understood that the World Health Organization and the team of scientists from the University of Rochester will continue to offer their expertise and assistance in a cooperative effort with the Iraqi Government and Iraqi scientists.

In addition to the National Science Foundation support for Dr. Clarkson's assistance to the Iraqis, the Dow Chemical Co. has also indicated its willingness to cooperate with the efforts of the University of Rochester team when it returns to Iraq.

The July 5, 1971, issue of Chemical and Engineering News reported that Dow has been providing Dr. Clarkson with sulfhydryl resin on an experimental laboratory basis. As described in this article and in an earlier article in the April 26, 1971, issue of the same magazine, this cooperative effort between the Dow Chemical Co. and the University of Rochester scientist was to test whether these resins, or various modifications of them, may be effective in binding methylmercury that has been ingested, and in increasing the rate at which mercury is excreted from the body by preventing reabsorption in the digestive

tract.

I might say the scientists, as is the nature of the discipline, have been careful in the claims made for this resin. However, in the handful of cases in which the resin was used in Iraq, a dramatic drop of the mercury content of the bodies of the individuals on which it was used was noted.

The resin captures the mercury in the digestive tract and it is then excreted from the body. So the scientists feel they may have a dramatic solution for mercury poisoning if the resin is given in adequate quantities and early enough.

If these resins could successfully act as a chemical magnet, which we believe they do, and accelerate the natural elimination of this poisonous heavy metal from the human body, an important breakthrough for helping moderate the gruesome effects of mercury poisoning would be achieved.

It would also immediately bring into mind the question as to whether this principle could be made applicable to other toxic heavy metals such as lead and cadmium.

So far the work on this sulfhydryl resin, so-called 17-B, had proceeded only on an experimental basis in the laboratory with tests on mice. When doctors from Iraq familiar with this study used experimental quantities of 17-B with Iraqi patients suffering dangerously high mercury blood levels, positive results were observed. The body content of methyl mercury was lowered without apparent side effects. This is particularly important in the cases of new mothers, since mercury is carried in the mother's milk, and the newborn baby can ingest enough mercury to cause serious harm.

The possibilities of utilization of 17-B in the Iraqi situation are of great interest. It is not a cure for mercury poisoning and will not reverse any symptoms of damage that already has occurred. Symptoms and damage from methyl mercury poisoning are thought to be a function of the quantity of mercury in the body and the length of time it takes naturally to eliminate the mercury.

Efforts to accelerate the rate of excretion of mercury from the body and lower the total mercury level may be important in preventing extreme symptoms or damage. In the case of children affected in the womb or through breastfeeding, the use of a substance which accelerated the flushing of mercury from the body could be extremely important.