world is for animal feed or fertilizer purposes, and it is not suitable for human consumption.

So we must bear in mind that what we are interested in here is upgrading the product by upgrading the plant in which it is made.

Mr. DINGELL. Is there a great similarity in manufacturing process between the making of fishmeal and the manufacture of fish protein concentrate?

Mr. BUCHANAN. Yes; there is some similarity.

Mr. DINGELL. Could you make the fish protein concentrate out of a fish fertilizer factory without too much difficulty?

Mr. BUCHANAN. No.

Mr. DINGELL. You could not?

Mr. BUCHANAN. No.

Mr. DINGELL. You indicated, though, that the processes are rather similar?

Mr. BUCHANAN. No; it would be quite difficult to convert any existing fishmeal plant to a fish protein concentrate plant.

Mr. DINGELL. Would the manufacturing steps be substantially similar insofar as manufacturing first, essentially what would be fishmeal; and then engaging in the extraction processes to produce the other? Mr. BUCHANAN. Not the existing fishmeal plant; no. They are not similar.

Mr. DINGELL. In theory, is fishmeal something very close to one of the steps in the manufacture of fish protein concentrate?

Mr. BUCHANAN. Some of the processing is similar, but the entire process, taken as a whole, is different.

Mr. DINGELL. You indicated to the committee some apprehension that it might be undertaken in a fishmeal plant, and suggest legislation to prevent that possibility.

Mr. BUCHANAN. Because we are concerned about not having a statement in the legislation which keys it to a product suitable for human consumption.

Such a plant could be made and operated to produce a product which is not acceptable for human consumption.

Mr. DINGELL. In other words, you could make fishmeal in a fish protein concentrate plant?

Mr. BUCHANAN. Yes.

Mr. DINGELL. What you are indicating to us is that you cannot make fish protein concentrate in a fishmeal plant?

Mr. BUCHANAN. Correct.

Mr. DINGELL. Could you use fishmeal as a raw material to manufacture a fish protein concentrate?

Mr. BUCHANAN. Not any that is available today.

Mr. DINGELL. But it is possible?

Mr. BUCHANAN. We don't know. We have not seen any that could be used, so that we cannot say that it is possible.

Mr. DINGELL. You are a Ph. D. who deals rather extensively in this field. I would assume that it would be fair to say that this is within the realm of possibility. Am I correct?

Mr. BUCHANAN. No; I would not make that assumption.

Mr. DINGELL. Would you categorically deny, then, that that is possible?

Mr. BUCHANAN. No, because I have no information to deny or confirm it. I would suspect, however, that the drying of fishmeal will change the components sufficiently so that they cannot be extracted to produce a bland product.

Some of the flavor precursors in fish are extracted in their native state prior to any drying operation in the Bureau of Commercial Fisheries process. Therefore, if you tried to use fishmeal which is a dried product, you would have denatured or changed those flavor precursors in such a way that you would not be able to extract them with the proposed process.

Mr. DINGELL. Let me ask you this. When we finish working on this legislation, if it is enacted, pilot plants are going to be constructed. What is going to happen to these pilot plants at the conclusion of the use by the Government, when the products come into popular use, if they do?

Mr. BUCHANAN. Well, I don't know. We would assume that at least some of them could be sold to industry.

Mr. DINGELL. For what purpose?

Mr. BUCHANAN. For the purpose of extending experimental work. Mr. DINGELL. What kind of experimental work?

Mr. BUCHANAN. Well, one never reaches a point of perfection in the development of a product that would permit no more experimental work at all.

We always are looking for ways to improve processing, or reduce costs, or improve product quality, and I should think that plant would be used for that purpose.

Mr. DINGELL. I see.

Thank you very much, Doctor.

Our next witness is J. Steele Culbertson, who is the director of the National Fish Meal & Oil Association.

STATEMENT OF J. STEELE CULBERTSON, DIRECTOR, NATIONAL FISH MEAL & OIL ASSOCIATION

Mr. CULBERTSON. Thank you, Mr. Chairman, for being permitted to testify.

I have a statement which I would like to read, if I may.

Mr. DINGELL. Would you give your full name and address for the record?

Mr. CULBERTSON. I am J. Steele Culbertson, director of the National Fish Meal & Oil Association, a division of National Fisheries Institute.

My appearance here today is solely on behalf of the members of this association who are engaged in commercial fishing and in the manufacture of fishmeal, fish oil, and fish solubles. Their operations extend along the coast from the southern New England States to Sabine Pass, Tex., and account for 80 to 90 percent of the total U.S. production of these products.

The raw material used for this purpose is derived primarily from menhaden, which is a member of the herring family, and the most abundant species harvested by U.S. fishermen. In some years menhaden accounts for over 40 percent, on a volume basis, of the total

landing of all commercial species, including the shellfish, that are caught and landed in the United States.

The record year, according to U.S. fisheries statistics, was in 1962, when menhaden landings exceeded 2.3 billion pounds.

In order to harvest and process this enormous fishery resource, the members of the National Fish Meal and Oil Association own and operate 30 large manufacturing plants on both the Atlantic and gulf coasts, from 500 to 600 fishing vessels, and 60 aircraft, having a total value in excess of $100 million.

People engaged in the industry, including fishermen and shore crews, number over 6,000, and many more are employed in the allied industries and businesses, such as shipyards, plant and machinery manufacturers, net and twine manufacturers, fuel companies, transportation companies, and many others.

My reason for giving you this background information about our industry is in order that you may better appreciate the size and importance of the menhaden fishing industry and resource and the potential both have in the future of FPC, as well as our interest in promoting its development and use.

Our industry has been in the forefront the past 4 to 5 years in promoting the development of FPC. On February 12, 1962, at our annual meeting, we met with Mr. McKernan, Director of the Bureau of Commercial Fisheries, for the purpose of discussing developments at that time that could have had important bearings on this matter.

There were:

1. A standard of identity for fish protein concentrate approved by the Food and Drug Administration and published in the January 25, 1962, issue of the Federal Register, which specified the use of fully dressed and eviscerated fish;

2. Ascertain what assistance the Bureau of Commecial Fisheries was prepared to offer in opposing this standard of identity and in getting the Food and Drug Administration to hold hearings on the question of using whole fish; and

3. Once such a hearing was announced what role the Bureau of Commercial Fisheries would have in the hearing.

In order to pursue this matter, a committee of our industry representatives was appointed and empowered to levy and collect assessments of up to $15,000 from the members, and to make decisions regarding our industries; participation in an overall program for the development of FPC.

As the first order of business, our committee prepared and sent Food and Drug a letter of protest against the standard of identity for FPC, utilizing dressed fish, which was published in the January 25 issue of the Federal Register, and instead asked for a standard of identity for FPC utilizing whole fish, and for a public hearing upon this matter.

The following is a quote from the objection we filed with the Food and Drug Administration:

Each of the members of our association will be adversely affected if the standard of identity for FPC as promulgated is placed into effect. This is by virtue of the fact that each member is actually or potentially a manufacturer of the food entity purported to be identified by the standard and the standard falls short of properly defining and standardizing the product. Cumulatively

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it is estimated that the members of this association would manufacture approximately 70 to 80 percent of the product sought to be defined by the standard of identity. At the present time these same members produce from 80 to 90 percent of the fish meal now manufactured in the United States.

During the next 2 or 3 months, our Committee on Fish Protein Concentrate, together with their attorney and members of the Bureau of Commercial Fisheries, held a number of meetings in Washington, D.C., to make preparation for a hearing that was set by Food and Drug Administration for June 12, that fish protein concentrate for human consumption.

Pursuant to the objection mentioned above that we had filed with Food and Drug Administration, the order establishing a standard of identity for fish flour utilizing fully dressed and eviscerated fish was rescinded.

Finally, however, after a few weeks of very careful study and analysis by our committee, working in conjunction with our attorney and the Bureau of Commercial Fisheries, it was decided that processes as of that time for the manufacture of FPC were not yet perfected, and it was our belief that we were confronted with an almost impossible problem in attempting to convince Food and Drug to issue a standard of identity for FPC manufactured from whole fish, when we did not really have a suitable process, and perhaps not a suitable product.

Upon reaching this determination, our industry committee, working closely with Government, decided to refer the matter to the Secretary of the Interior, and asked if he would use the facilities of his good office and get the National Academy of Sciences to initiate a study by an appropriate group under their supervision on the product and the processes.

Accordingly, on May 31, the Secretary of the Interior sent a letter to Dr. Bronk, president, National Academy of Sciences, requesting this action, and, as you all know, these studies have been made and favorable findings and reports rendered.

Using a copy of the letter of the Secretary of Interior to the National Academy of Sciences, we then had our attorney write to the Food and Drug Administration and request indefinite postponement of the hearing on the proposed standard of identity for FPC made from whole fish.

Accordingly, we were notified by FDA that the hearing was indefinitely postponed, without prejudice.

Now, 3 or 4 years later, and with the work that has been done in the meantime by the Bureau of Commercial Fisheries and by members of our industry on the development of a suitable process and product for FPC, it seems that we are on the threshold of being able to commence the commercial manufacture of this product, just as soon as approval is given by the Food and Drug Administration.

Although we have made a long stride in this direction, we feel there is still need for further support by Government to assist industry in the final development of this product.

Accordingly, we wish to offer our wholehearted support for approval and passage of H.R. 16619 and S. 2720, and similar bills.

In this connection, it is our belief that menhaden, the most abundant U.S. species harvested, is highly suitable for the manufacture of FPC,

and that one of the plants that would be authorized by this bill be established on the Atlantic, and one on the gulf for this purpose. Thank you.

Mr. DINGELL. Mr. Pelly.

Mr. PELLY. I would like to ask Mr. Culbertson in what area the largest menhaden resource is located. Is it off North Carolina? Is that right?

Mr. CULBERTSON. They have been harvested all the way, Congressman Pelly, from the southern New England States and along the entire Atlantic coast, and in recent years the resources in the gulf is equally as large or larger than it is in the Atlantic. They harvest in the gulf off Mississippi, Louisiana, and Texas, primarily.

Mr. PELLY. How far out from the coastal shore are they harvested? Mr. CULBERTSON. The great part of them are harvested inside of 12 miles and, perhaps the larger part inside of 3 miles.

Mr. PELLY. Which reminds me that I have heard today that the Japanese are building 300 more fishing boats. I wonder if we are going to spend a lot of money developing the utilization of menhaden, and what if the foreign countries come right inside of the 12-mile limit and take this resource away? Will we not be throwing away our money?

Mr. CULBERTSON. We really don't have any to spare and we would hope that they will not come in and start fishing on them.

Mr. PELLY. I know that we have considerable in the way of fisheries resources on the Pacific coast that the Russians are sending their fleet of fishing vessels to harvest. Now, with the Japanese, I think we have to take some steps to protect our resources, even if we only can do so within 12 miles.

It seems that the fishing industry would rather go elsewhere and get their product, rather than protect what we have ourselves.

Mr. CULBERTSON. We really don't have much to spare, certainly not of menhaden.

Mr. PELLY. Let's keep them to ourselves, then, and have a 12-mile fishing zone.

Thank you, Mr. Chairman.

Mr. DINGELL. Mr. Dow.

Mr. Dow. You have offered very valuable testimony, Mr. Culbertson. If we went ahead and made arrangements for using the menhaden, I guess in the condition of not being dressed, would that mean you could harvest a lot of more menhaden than you do now?

Mr. CULBERTSON. I don't think that would have any bearing on that, Congressman Dow. We are utilizing practically all the menhaden we can get today in the manufacture of fish meal. It has become a very valuable high protein item in poultry feeds.

As a matter of fact, we import from Peru as much or more than we produce locally for feed purposes.

Mr. Dow. In other words, you are saying that you are now harvesting as much menhaden as you believe you can, and converting that to fishmeal. For what purpose do you use the fishmeal?

Mr. CULBERTSON. Almost all of it goes into poultry feed. It is a high protein additive that has all the essential amino acids that are conducive to growth of the young animals.