Not a single tolerance has been established under the Food Additive Amendment for 
any standard insecticide or fumigant to be used in the entire processed food and animal 
feed field. There are extensions granted for the use of pyrethrum plus piperony]l butoxide 
and a few of the common fumigants in food plants. Through prior approval pyrethrum and 
piperonyl butoxide can be used as a treatment for multiwall paper bags. 
The reason for the state of confusion and the lack of tolerances is that essentially no 
scientific research has been conducted on the use of pesticides in food processing plants. 
Background knowledge about the properties and other uses of materials has been drawn 
upon as the basis for estimating by inference what might happen ifthey were used in food 
plants. By trial and error general observations have been made as to which materials 
are effective in practical use. 
There is an urgent need to determine which pesticides can be used safely as well as 
effectively under the numerous and diverse conditions that exist in food plants. Attention 
must also be given to where and how the materials are applied within food plants. There 
must be residue analyses on the product from the normal flow line to determine whether 
or not contamination results from various uses of different pesticides. Dr. Byerly has 
referred to the difficulty of insuring that we can meet zero tolerances and stated that it 
is not possible to prove absence of residue but only presence. Therefore, the research 
of which I speak will be time-consuming and complicated but it appears evident that 
eventually the work must be done. 
In the meantime, those who use pesticides and those who make recommendations for 
their use in food plants have only the most general guides for procedure. About the best 
we can do is to say that pesticides shall be used so food will not be contaminated. In the 
absence of residue data there are many borderline circumstances where nobody is quite 
sure whether or not contamination will result. There are differences of opinion among 
regulatory officials as well as among researchers as to what constitutes a hazardous 
use. Strong personnel opinions are sometimes based on prejudice rather than fact. Until 
more facts are known we need some sound thinking and a lot of commonsense to provide 
guidelines to the industries involved as well as to regulatory agencies. This would also 
serve to settle much of the apprehension and anxiety that now exist. 
TRANSPORTATION FACILITIES 
Another urgent problem area for the food, grain, and feed industries is the infesta- 
tion hazard during transit in railway cars, trucks, and ships. Commodities that become 
infested in transit may be refused by the customer or subject to action by the Food and 
Drug Administration. Either procedure is costly and of considerable importance to the 
shipper or processor. 
Better ways must be found to eliminate infestations in transportation facilities and to 
protect commodities against insect invasion during transit. The procedures developed 
must not cause residues or have other adverse effects on the commodity. 
The problem has become so acute in rail transportation that we are setting upa 
project to get some exploratory work startedonit. There has been a considerable amount 
of discussion recently about the insect problem in ships, but we are not in a position to 
start any work along these lines now. This situation should not be permitted to continue 
indefinitely. When our grain and other productsareinfested upon arrival at foreign ports, 
it casts a reflection on the quality of our goods and this is detrimental to international 
trade. The recipients may not realize, or care, that the products were insect-free when 
shipped and that the infestation occurred in transit. Infested ships also increase the 
hazard of introducing harmful pests into this and other countries. As an example, the 
port inspectors are finding an increasing number of ships and cargoes infested with the 
khapra beetle right at a time whenwe have exerted a great deal of effort toward eliminat- 
ing the known infestations in our country. 
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