December 10, 1998

Hon. Donna Shalala, Secretary
U.S. Department of Health and Human Services
200 Independence Ave. SW
Washington, DC 20201

Dear Secretary Shalala:

The International Agency for Research on Cancer (IARC), a unit of the World Health Organization, reviews the safety of many significant chemicals to which humans may be exposed. IARC, which is funded in part by the National Cancer Institute, has enjoyed an excellent reputation due to the credibility of scientists who served on IARC’s review committee and the objectivity of its reports. Unfortunately, IARC apparently has lost its objectivity.

IARC has just completed a review of the artificial sweetener saccharin. The committee’s conclusion -- that saccharin does not pose a cancer risk -- was virtually predetermined by the composition of the committee. The 26-person committee (two additional people could not attend) was dominated by industry representatives and industry consultants. Those people include:

Two additional members -- J. Whysner and G.C. Hard -- work at the American Health Foundation, an organization whose board of directors includes IARC-committee-member R.H. Adamson from the National Soft Drink Association and executives of Pepsi-Cola and Procter & Gamble. Whysner has published papers stating that saccharin does not pose a risk to humans, and Hard was a co-author and colleague at the NCI of J. Rice, the organizer of IARC evaluations.

Thus, fully half of the people on the committee are affiliated with the food and chemical industries and/or had previously concluded that saccharin does not pose a cancer risk. By contrast, the committee did not include any members, such as ones nominated by consumer or environmental organizations, who might have balanced the lopsided industry representation. In fact, IARC specifically rejected CSPI’s request to nominate a scientist to participate as a non-voting member of the committee. Frankly, it appears that the review was carefully rigged to exonerate saccharin.

Aside from the extraordinary conflicts of interest, IARC’s evaluation was completely inadequate from a scientific standpoint (see enclosed):

The IARC committee was so biased and its evaluation of saccharin so unscientific that DHHS (and the WHO) should demand that IARC withdraw its report. The WHO should appoint a new director for its chemical evaluation process, appoint a new and balanced committee of unquestioned integrity, and then reevaluate saccharin. Failing that, DHHS should cease funding IARC. Also, DHHS should postpone any further deliberations related to saccharin’s status in the government’s Report on Carcinogens (a year ago the National Toxicology Program’s Board of Scientific Counselors voted to leave saccharin in that report; the NTP’s executive committee is scheduled to vote next week).


Michael F. Jacobson, Ph.D.
Executive Director
Center for Science in the Public Interest


Also signing on behalf of:

Richard Clapp, D.Sc., associate professor, Department of Environmental Health, Boston University, Boston, Massachusetts

Marvin Legator, Ph.D., professor and director, division of environmental epidemiology, University of Texas Medical Branch, Galveston, Texas

William Lijinsky, Ph.D., Columbia, Maryland, former director, chemical carcinogenesis program, Frederick Cancer Research Center, National Cancer Institute, Frederick, Maryland

Melvin D. Reuber, M.D., Columbia, Maryland, consultant in human and experimental oncology and pathology; former staff pathologist, National Cancer Institute; former chief, pathology laboratory, Chemical Carcinogenesis Program, Frederick Cancer Research Center