most limitless, and so is the range of industries t h a t are affected.
The Hercules Story P r o b a b l y no group has greater interest in the problems of indirect additives than the food packaging industry and its suppliers—those companies which provide the m a t e rials of which packages are made. Their representatives had been watching the proceedings leading to writing of the Food Additives Amendment long before the bill actually became law. F o r those who maintained a faithful vigil, who were able to interpret the trends correctly, and who started action in conformance with their interpretations, the rewards of this close observation are being realized. Hercules Powder Co. and its polypropylene resin provide a good example of this. B y the end of 1957 it was a p p a r e n t to company officials t h a t passage of a Food Additives A m e n d m e n t was inevitable, so the company began working t o ward a petition in September 1957. The pay-off came on April 16, 1960, when the company's polypropylene rosin became the first new (not used before J a n u a r y 1, 1958) substance to meet legal requirements is a food packaging material. This adds up to 31 months required to do the experimental work, prepare and submit a nearly 300-page petition, and get a formal regulation published in the Federal Register. T h e reasoning and work t h a t went, into the project had several unique aspects. N o t only were the toxicological questions answered in an unusual, rapid, and convincing m a n n e r ; but the k n o t t y problem of regulatory testing of individual foods for polypropylene migrants was by-passed in a way which could be precedent for future petitions. The extent of migration of packaging materials to foods can be clearly demonstrated in experimental laboratory work; but the tedious and time-consuming methods involved certainly do not lend themselves to regulatory work on commercial shipments. Looking for another approach to the situation, Hercules then adopted the possibility of regulating the mi-
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VOL.
33, NO. 1, JANUARY 1961
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29 A
