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FDA Compliance

The American Chamber of Horrors

How a public exhibit led to the 1938 Food, Drug, and Cosmetic Act

Published: Thursday, July 26, 2018 - 12:01

During the early 20th century, Americans were inundated with ineffective and dangerous drugs, as well as adulterated and deceptively packaged foods.

A cosmetic eyelash and eyebrow dye called Lash Lure, for example, which promised women that it would help them “radiate personality,” in fact contained a poison that caused ulceration of the corneas and degeneration of the eyeballs. An elixir called Banbar claimed to cure diabetes as an alternative to insulin, but actually provided no real treatment and caused harm to those patients who substituted this for effective insulin therapy.

Food producers short-changed consumers by substituting cheaper ingredients. Some products labeled as peanut butter, for instance, were filled with lard and contained just a trace of peanuts, and some products marketed as “jellies” had no fruit in them at all. Unscrupulous vendors even sold products to farmers, falsely promising they could treat sick animals—in at least one case, a product called Lee’s Gizzard Capsules killed an entire flock of turkeys instead of curing them.

Although the U.S. Food and Drug Administration (FDA) sought to remove these unsafe and misleading products from commerce, it was severely limited in its efforts by the 1906 Pure Food and Drugs Act. That law laid the cornerstone for the modern FDA and marked a monumental shift in the use of government powers to enhance consumer protection, by requiring that foods and drugs bear truthful labeling statements and meet certain standards for purity and strength.

Over time, however, the shortcomings of the Pure Food and Drugs Act became apparent because it failed to take into account the extraordinary changes in industries, products, markets, and advertising tactics. Dangerous drugs were a particular problem. As long as a drug met the law’s labeling requirements, the agency did not have the authority to remove even clearly dangerous products, such as radium water and drugs with poisonous ingredients, from the market because legal action against a drug product required a finding of fraud. If a drug’s maker could convince a court that he truly believed his own therapeutic claims, he won his case. In addition, the law provided no authority over cosmetics or medical devices, and did not specifically authorize standards for foods, which limited the agency’s ability to take action on behalf of consumers.

A popular book of the day, 100,000,000 Guinea Pigs: Dangers in Everyday Food, Drugs, and Cosmetics, by Arthur Kallet and F. J. Schlink (Grosset & Dunlap, 1933), claimed that consumers were being used as guinea pigs in a giant experiment by food companies and makers of patent medicines, with the authors blaming the FDA for failing to act. But the critics failed to acknowledge the limits of the agency’s authority under the law at the time.

In an effort to inform the public about the 1906 law’s shortcomings, the FDA’s chief education officer, Ruth deForest Lamb, and its chief inspector, George Larrick, led the creation of an influential traveling exhibit in 1933 to highlight about 100 dangerous, deceptive, or worthless products that the FDA lacked authority to remove from the market.

The exhibition was put on display at events like the 1933 World’s Fair in Chicago, at state fairs, and on Capitol Hill. It was so shocking that it was dubbed the “American Chamber of Horrors” by a reporter who accompanied First Lady Eleanor Roosevelt to view the exhibit. Lamb also adapted the exhibit into a 1936 book in which she explained, “All of these tragedies... have happened, not because Government officials are incompetent or callous, but because they have no real power to prevent them.”

The exhibit, which was viewed by millions, was an enormous success, helping promote greater awareness and understanding about the FDA’s role in protecting the public, the need for greater consumer protection, and the limitations on the FDA’s power to do so. To this end, it played an important role in moving Congress to enact a stronger food and drug law—the 1938 Food, Drug, and Cosmetic Act.

The 1938 law, which has been amended many times and remains the law of the land today, brought cosmetics and medical devices under the FDA’s authority, and required that drugs be labeled with adequate directions for safe use. It also mandated premarket approval of all new drugs, such that a manufacturer would have to prove to the FDA that a drug was safe before it could be sold. And it prohibited false therapeutic claims for drugs. The act also corrected abuses in food packaging and quality, and it mandated legally enforceable food standards. It formally authorized factory inspections, and added injunctions to the agency’s enforcement tools. In short, it gave the FDA many of the means it has today to protect the American public.

Many of the products from the original Chamber of Horrors exhibit are in the FDA’s permanent collection, and to commemorate the 80th anniversary of the 1938 law, they are part of a special display currently on exhibit at the FDA. The objects provide a compelling visual record of how far science has brought us from the worthless and dangerous elixirs, foods, and other consumer products of the early 20th century, as well as underscoring the essential role the FDA today plays in protecting and promoting American health.


About The Authors

Vanessa Burrows’s picture

Vanessa Burrows

Vanessa Burrows is a historian at the U.S. food and Drug Administration (FDA).

Suzanne Junod’s picture

Suzanne Junod

Suzanne Junod is an FDA historian.

John Swann’s picture

John Swann

John Swann is an FDA historian


Upton Sinclair was right.

The purpose of Upton Sinclair's "The Jungle" was to expose the plight of immigrant workers, but most readers never got around to that part of the book because they focused on the intimate details of the meat packing industry. Chapter 14 (https://www.gutenberg.org/files/140/140-h/140-h.htm) is highly instructive but I don't recommend reading it before a meal (or immediately afterward). This helped pass the Pure Food and Drug Act of 1906 which, while subject to the limitations the authors describe here, was at least a good start. https://www.loc.gov/rr/news/topics/purefood.html uses the phrase "human guinea pigs" to describe the situation at the beginning of the 20th century.

The exhibit cited in the article (https://www.fda.gov/AboutFDA/History/VirtualHistory/HistoryExhibits/ucm6...) is highly instructive. Here is a clever scam that did not involve a single word of false advertising: "Egg Noodles have slightly more nutritive value than other marketed dried pastas and were slightly more expensive. An enterprising manufacturer tried to convince consumers that his pasta was actually egg noodles by packaging them in yellow cellophane to give them a yellow tinge that would have let a consumer distinguish between egg noodles and pasta." (The product was however labeled honestly as plain noodles.)

This one dates back to Greek mythology (Trick of Mecone), in which Prometheus urged mortals to deceive Zeus by putting a layer of snow-white fat over gristle and other wastes, and gristle over the best meat, and inviting Zeus to pick his own offering. "Veneered Chicken Was a deceptive packaging scheme that was typical of the time. The more expensive white mean was placed in this jar in a thin outside layer that disguised the fact that most of the contents included dark meat." Watch out for this trick today, in which vendors display salads with a thin layer of chicken and cheese on top, but which are mostly lettuce.

And even the 1938 reforms are apparently not enough to protect us from everything, as shown by the popularity of colloidal silver. https://nccih.nih.gov/health/silver "The FDA also warned in 1999 that colloidal silver isn’t safe or effective for treating any disease or condition."