488 



Statement of 



Sherwin Gardner, Consultant 



before the 



House Subcommittee on Health and the Environment 



March 25. 1994 



Members of the Subcommittee, my name is Sherwin Gardner. I am an 

 independent consultant to industry specializing in issues arising from 

 regulation of food and other products by the Food and Drug 

 Administration. My experience includes 13 years as Senior Vice 

 President for Science and Technology with the Grocery Manufacturers 

 of America, and seven years as Deput>' Commissioner of the Food and 

 Drug Administration. I am here at the request of Philip Morris U.S.A., 

 which retained me to review its tobacco processing and cigarette 

 manufacturing practices in light of recent allegations regarding 

 manipulation of the nicotine content of cigai-ettes. 



To do this. I visited several Philip Morris manufacturing facilities in 

 the Richmond. Virginia area. I was accompanied by two consultants 

 from the Weinberg Group, an independent technical consulting 

 organization, who are experienced in auditing food and drug 

 manufacturing facilities in the United States. The assistance of these 

 consultants was requested by me. and they served under my 

 supervision. Biographical statements about myself and the two 

 consultants are included in the accompanying report that I am 

 submitting for the record. The information presented to the 

 Subcommittee is based on the observations made and the interviews 

 conducted with Philip Morris personnel during these visits. We sent 



