Exhibit 5 OPINION OF COUNSEL ------------------ The Procter & Gamble Company General Offices 1 Procter & Gamble Plaza, Cincinnati, Ohio 45202-3315 October 4, 1996 The Procter & Gamble Company Procter & Gamble Pharmaceuticals, Inc. One Procter & Gamble Plaza Cincinnati, Ohio 45201 As Tax and Legal Counsel-Employee Benefits for The Procter & Gamble Company, I have reviewed the written documents constituting the Giorgio Employee Savings Plan, as amended, and believe it is qualified under Section 401(a) and is exempt from tax under Section 501(a) of the Internal Revenue Code. The written documents constituting the Giorgio Employee Savings Plan, as amended, are in compliance with the requirements of ERISA. Sincerely, /s/REBECCA R. LAWRENCE - ----------------------- Rebecca R. Lawrence Tax & Legal Counsel, Employee Benefits