The United States Pharmacopoeia is a book preparedby a national organization chosen by the medical and pharmaceutical colleges andsocieties of the country. This organization meets once in each ten years. The principalobject of these decennial conventions is to appoint a committee for revising theUnited States Pharmacopoeia. At the Convention which assembled in Washington in 1910,much to my surprise, I was elected president of the Convention for the decennialperiod ending in 1920. Ex officio I became a member of the committee on revision.The food-law specifically recognizes the United States Pharmacopoeia, both as tothe standard of quality of the remedies described therein and the methods of analysisby which the purity of remedies is established. Its activities, therefore, are specificallyprescribed by the Congress of the United States as one of the methods of administeringthe Food and Drugs Act. Essential oils are frequently standardized and prescribedin the Pharmacopoeia. I was allowed to select the particular part of the revisionwork over which I was chosen to preside. I had for several years, on account of essentialoils being agricultural products, collected and studied large numbers of these bodies.This work was assigned to the committee studying essential oils. I was very muchsurprised, therefore, to receive from the Secretary of Agriculture a written statementfor the amount of time consumed in these investigations and the probable expenseto date of the work done. Any one who is interested in the further details of thisremarkable request will find them recorded on page 808 and following of the proceedingsof the Moss Committee.

   The methods of analysis and the standards ofpurity of drugs prescribed by the Pharmacopoeia are specifieally adopted by the Foodand Drugs Act. The regulations enacted for the enforcement of the Food and DrugsAct are as follows:

   Unless otherwise directed by the Secretary of Agrieulture, the methods of analysis employed shall be those employed by the Amociation of Official Agricultural Chemists and the United States Pharmacopoeia.

   I made the following statement to the committee:

   I may say, Mr. Chairman, that never in the history of the Pharmacopoeia has such pains been taken to make it as perfect as possible. In view of the fact that Congress has made it the official standard of drugs and medicines, the present committee is taking special pains to get all the information possible to make the new edition as useful as possible, for the purpose of securing purity of drugs in this country.

   During my absence from the city I was informedby the Secretary of Agriculture on June 15 that Dr. Dunlap had told him he had informationthat work was going on in the Bureau of Chemistry in the revision of the Pharmacopoeia.

   When Dr. Dunlap appeared as a witness beforethe committee he was asked: "What are your duties as associate chemist?"

   He replied: "I have none."

   Evidently he was mistaken. It was he who by hisdetective abilities discovered that the Chief of the Bureau of Chemistry had deceivedthe Secretary of Agriculture and induced him to appoint Dr. Rusby illegally. Continuingthe exercise of these Sherlock Holmes activities he discovered the Bureau of Chemistrywas doing illegal work in examining the agricultural products known as essentialoils. These were noble and important functions that somebody had to perform. It wasa great stroke of good luck that put Dr. Dunlap into the Department for this worthypurpose. President Roosevelt deserves the gratitude of the future for discoveringand having appointed a scientist of such ethical activities and achievements. Asa result of Dr. Dunlap's activities the Solicitor had told the Secretary that theseactivities of the Chief of the Bureau were clear violations of law and the Secretaryinstructed me to do no more work of any kind in connection with revision of the Pharmacopoeia.At this same time the members of the Referee Board were paid salaries exactly asDr. Rusby was and had spent already several hundred thousand dollars in their attemptsto prevent the food law from being enforced. I found that the total expense whichhad been incurred by the Bureau of Chemistry up to the time the order was issuedto "cease and desist" from these activities as violations of law was exactly$55. Of all the tremendous inconsistencies in regard to illegal expenditures in theBureau of Chemistry in connection with the Remsen Board, there was nothing so clearlyand distinctly disclosed as the complete propriety of the activities of the Bureauof Chemistry in securing a proper revision of the Pharmacopoeia. This order forbiddingwork in the Bureau of Chemistry along that line was still in force in 1912 when Iretired from the Bureau. I do not think it was removed during the remainder of mydecennial term.

   This pusillanimous persecution of itself amountsto nothing. It illustrates the petty meanness of the environment which the Chiefof the Bureau was forced to endure for so many years. The report of the Moss Committeedisclosed the whole fabric of the net in which the enemies of the food law had plannedto enmesh those charged by law to enforce it. In regard to this matter the followingquotation from the Moss Committee's record' is illuminating:



   Page 887-888.

   THE CHAIRMAN: Did I understand you correctly in your testimony,when I was asking questions, to say you can extend the functions of the Bureau ofChemistry, provided it is not prohibited by law?

   SECRETARY WILSON: I can use administrative discretion that isnot prohibited by law. * * * I can illustrate that by what happened at Denver. Dr.Long is a member of the Referee Board from Chicago. There had been going throughthe papers and being stated by the chemists, and so forth, that the best use to whichwe could put benzoate of soda, and the use to which it generally was put, was topreserve decaying vegetables and fruits. Dr. Long had made some extensive investigationsand reported there that benzoate of soda would not preserve either vegetables orfruits.

   THE CHAIRMAN: Did I understand you to say, in answer to Mr.Sloan, that there was no authority in law for this pharmacopoeia work--that it wasabsolutely forbidden by law to do this work?

   SECRETARY WILSON: No authority.

   THE CHAIRMAN: Coming back to your idea that you can extend thefunctions of the Bureau of Chemistry, providing it is not forbidden by law, wouldyou not have authority, under your construction, to permit Dr. Wiley to do this workif you had cared to do so?

   SECRETARY WILSON: No; administrative discretion can only beused in furtherance of the object of the law.

   Page 894-895.

   MR. HIGGINS: Have you pursued, Mr. Secretary, any differentpolicy toward the Chief of the Bureau of Chemistry than with reference to any otherchief in your department?

   SECRETARY WILSON: Not a particle. You could not understand,if you happened to look over the transom of the door and see Dr. Wiley and me discussingone of his new farms

   MR. HIGGINS (interposing): He is also an agriculturist?

   SECRETARY WILSON: He has farms, but he and I discuss them. Igive him advice. I am no chemist; but, then, he is no farmer (laughter), and so weswap information, you know. There is one delightful thing about the Doctor: he hashumor, and unless I once in awhile get a laugh I would run back to Iowa and staythere. The Doctor has pleasant humor, and he is a pleasant companion. If you sawus in one of these interviews you would not believe there ever was any trouble aboutbenzoate of soda.

   MR. HIGGINS: You discuss pleasant subjects at those interviews?


   MR. SLOAN: You are both bonnie Scots, are you not?

   SECRETARY WILSON: I am direct, but I imagine he is tainted withthe blood.

   The Bureau of Chemistry was not treated likeother Bureaus. Secretary Wilson was well aware of that fact. In no other Bureau didhe appoint an Associate Chief, as he did in the Bureau of Chemistry, without everconsulting the Chief of that Bureau. In no other bureau were funds specifically appropriatedfor definite purposes used without the consent of the chief for diametrically oppositepurposes. In no other Bureau were changes made in administration without consultingthe Chief of the Bureaus involved. No other Chief of Bureau was ever secretly triedbefore the personnel board, found guilty, and sentenced to be dismissed from theservice, as was the Chief of the Bureau of Chemistry. In no other Bureau were importantcomponent parts thereof separated and put into an independent bureau as was the casein the Bureau of Chemistry with Soils and Investigations of Road Building Materials.While it is true that the Secretary and the Chief of the Bureau were on friendlyterms personally, the Secretary never took the advice of the Chief of the Bureauof Chemistry on the important matters above mentioned. In no other bureau were fundsappropriated for a specific purpose used for paying employees who were ordered toreport to the Solicitor of the Department. These are only a few of the illustrationsof the different treatment accorded to the Bureau of Chemistry.



   Page 644.

   THE CHAIRMAN: Will you please state your precise duties as existingin the department when you are not acting as chief chemist; what are your preciseduties today in the Bureau of Chemistry?

   DR. DUNLAP: I am associate chemist of the Bureau of Chemistryand member of the Board of Food and Drug Inspection.

   THE CHAIRMAN: As associate chemist, what are your duties?

   DR. DUNLAP: I have no duties.

   THE CHAIRMAN: Then, having no duties as associate chemist, yoursole duty is as a member of the Board of Food and Drug Inspection?

   DR. DUNLAP: Exactly.

   Dr. Dunlap seems to forget the important office be was to perform,namely, to see that the Chief of the Bureau did no unauthorized work to make theofficial standard of drugs as perfect as possible.