THE ANALYST. 97 REGULATIONS FOR MILK AND CREAM. REPORT OF THE DEPAHTMENTAL COMMITTEE APPOINTED BY THE BOARD OF AGRICULTURE TO INQUIRE INTO AND REPORT UPON THE DESIRABILITY OF REUULATIONS (UNDER SECTION 4 OF THE SALE OF FOOD AND DRUGS ACT, 1899) FOR MILK AND CREAM. AT the beginning of 1900 the Board of Agriculture, in pursuance of their powers under Section 4 of the Sale of Food and Drugs Act, 1899, appointed a Departmental Committee to inquire and report what regulations, if any, should be made in the case of milk and cream for determining what deficiency in the normal constituents, or what addition of extraneous matter, should be held to raise a presumption that the milk or cream was not genuine. This Committee consisted of the following members : Lord Wenlock, G.C.S.I., G.C.I.E.(Chairman) ; Mr. George Barham (Dairy Supply Co., London) ; Mr. George Cowan (Dairy Farmer, Wigtownshire, N.B.) ; Major Craigie (Assistant-Secretary Board of Agriculture) ; Mr. S. W. Farmer (Dairy Farmer, Little Bedwyn, Wilts) ; Dr. Shirley F. Murphy (Medical Officer, London County Council) ; Professor Thorpe, F.R. S. (Principal Chemist, Government Laboratories) ; Dr. J. A. Voelcker (Consulting Chemist, Royal Agricultural Society of England) ; with Mr. R. H. Rew (Board of Agriculture) as Secretary. The Report of the Committee was made to the Board of Agriculture, and, having been presented to both Houses of Parliament, has now been published, together with the Minutes of Evidence taken before the Committee. The Committee held fifteen sittings for the purpose of taking evidence, and examined forty-nine witnesses.Of these, fifteen were analysts, and included names so well known as Mr. A. H. Allen, Mr. E. J. Bevan, Sir Charles Cameron, Mr. C. E. Cassal, Dr. Dyer, Mr. W. W. Fisher, Dr. Alfred Hill, Mr. G. Lewin, Mr. F. J. Lloyd, and Mr. H. D. Richmond. Four witnesses were Medical Officers of Health (for Birmingham, Glasgow , Manchester and Reading respectively) ; while the views of the Dairy Trade, the milk-prcducing farmers, agricultural societies, and Dairy Farmers’ Associations, were all fully represented, and the evidence comprised in a Blue Book of 450 pages. The Report itself is in two parts, the majority report, signed by seven of the eight members, comprising thirty-three pages. I t is subject, however, to a reservation by one of the signatories, Mr.S. W. Farmer, who is in favour of c‘sea~onal limits.” The minority report, which extends to thirty-six pages, and traverses the whole ground of the majority report, is signed by Mr. George Barham alone. The subjects, considered in order, were: (1) Whole milk; (2) skimmed or separated milk ; (3) condensed milk ; (4) cream. There was a general consensus of opinion that there ought to be regulations laid down for determining when milk and cream should be considered genuine, though some few witnesses, mostly repre- sentatives of dealers in and distributors of milk, thought that no such regulations were necessary. standards ” adopted in different The variability of the so-called98 THE ANALYST. towns and by different analysts was brought out, and a general desire expressed that uniformity should be arrived at.The Report next deals with the various difficulties standing in the way of fixing limits. ‘‘ Ninimal limits,” it may be said, is the sense in which the Committee inter- pret the expression ‘‘ standard ” now so generally used. The causes of variability in the quality of milk, viz., the land, the method of feeding (the influence of which is not regarded as definite), the breed, condition, period of lactation, interval between times of milking, the time of year, etc., are.successively dealt with. The ‘‘ standards ” adopted in other countries are set out, but are not considered to have much bearing on the subject immediately in hand. The question is then discussed very fully whether (‘ local limits,” applying to particular districts, or ( ( seasonal limits,” apply- ing to particular times of the year, could be adopted; and whether milk could be “ graded ” according to quality, and sold as of certain grades and at corresponding prices.The Report shows the impracticability, in the Committee’s opinion, of all these suggestions, though the question of “ seasonal limits ” called for, as it merited, very careful consideration, and it was on this point alone that Mr. Farmer, one of the Committee, found it necessary to append his reservation when signing the general Report. The general feeling of the Committee was that though, as a rule, it would be in the months of May and June that milk would be somewhat lower in quality, yet there might be great variation in particular years, and that any concession given for certain months and particular cases would lead to much greater difficulties as regards the administration of justice, while the difficulties of the producer could be met partly by his own efforts in insuring regularity and uniformity of supply, and partly by the reasonable application of the proposed “limits” by those responsible for administering the Act.limits ” to be adopted, the Committee have clearly been guided mainly by the views of those who-such as the analysts-have no personal interest in the matter, but are conversant with the chemical examination of milk as supplied to the public and during all times of the year. It is pointed out that while farmers generally favoured a limit of 3 per cent.of fat, and in several cases expressed a preference for a higher limit, the representatives of the traders in milk, almost without exception, advocated a low (‘standard ” or none at all. A large number of statistical tables were put in giving the results of analyses of samples of milk taken over considerable periods and as supplied to different dairies, creameries, etc., over the country, and the Committee arrived at the conclusion that the milk produced for sale, as such, in this country contains, on an average, from 12.5 to 12.8 per cent. of total milk-solids, comprising from 3.7 to 4 per cent. of milk-fat. After weighing carefully the evidence given them, and especially that of the analysts, they came to the conclusion that any milk the total milk-solids of which fall below 12 per cent.should be made the subject of ‘‘ further inquiry.” If it should then be found to give less than 3-25 per cent. of milk-fat, it is recommended that a presump- tion be raised-until the contrary is proved-that it has been mixed with separated milk or water ; and, if the non-fatty milk-solids are less than 8-5 per cent., the pre- sumption that it has been mixed with water shall arise. Accordingly, the governing factor in the first instance is to be that of a, limit of In dealing next with the particularTHE ANALYST. 99 12 per cent. of total milk-solids, and it is only when a milk fails to give this per- centage that it is further inquired into, and the other factors, viz., 3-25 per cent. of fat and 8-5 per cent. of non-fatty solids, come into force.It is well that this should be clearly explained, as a good deal of misapprehen- sion appears to exist on the point, The Report next puts out certain suggestions for the better administration by local authorities of their powers under the Act, whereby the interests of the honest trader may be safeguarded. Uniformity in methods of taking samples and of analysis is advocated, as well as the official standardizing of (‘ mechanical test ” bottles. I n regard to hand-skimmed and machine-separated milk the Committee think that there is no necessity to make a distinction between them, but that both should be sold under a ‘‘ limit ” of 9 per cent. of total milk-solids. They further give their opinion that it would be very desirable to identify or ear-mark ” all separated milk.The subject of Condensed Milk also occupied the attention of the Committee, and there was strong expression as to the necessity of limiting the amount of sugar used in these preparations, and to the securing that the milk, when diluted with water to the extent stated on the label, should be judged by the limits for ordinary milk. I t was recommended, therefore, that condensed milk should contain not less than 10 per cent. of fat or 25 per cent. of solids-not-fat. Lastly, as regards cream, the Committee did not advocate the fixing of any definite limits of fat, etc., but they considered that cream might well be sold as of different qualities, at corresponding prices. They advised, however, that any artificial thickening of cream should be considered as an adulteration.To the five main recommendations which they give in their Report the Committee append seven minor suggestions as expressions of opinion, and the whole are set out 8 s follows : RECOMMENDATIONS. 114. The Committee beg to make the following recommendations : I. That regulations under Section 4, of the Food and Drugs Act, 1899, be made by the Board of Agriculture with respect to Milk (including condensed milk) and Cream. 11. (a) That in the case of any milk (other than skimmed, separated, or con- densed milk) the total milk-solids in which on being dried at 100 degrees Centigrade do not amount to 12 per cent. a presumption shall be raised, until the contrary is proved, that the milk is deficient in the normal con- stituents of genuine milk.( b ) That any milk (other than skimmed, separated, or condensed milk) the total milk-solids in which are less than 12 per cent., and in which the amount of milk-fat is less than 3.25 per cent., shall be deemed to be so deficient in milk-fat as to raise a presumption, until the contrary is proved, that it has been mixed with separated milk or water, or that some portion of its normal content of milk-fat has been removed. In calculating the per- centage amount of deficiency of fat the analyst shall have regard to the above-named limit of 3.25 per cent. of milk-fat.100 THE ANALYST. (c) That any milk (other than skimmed, separabd, or condensed milk) the total milk-solids in which are less than 12 per cent., and in which the amount of non-fatty milk-solids is less than 8.5 per cent., shall be deemed to be so deficient in normal constituents as to raise a presumption, until the contrary is proved, that it has been mixed with water.In calculating the percentage amount of admixed water the analyst shall have regard to the above-named limit of 8.5 per cent. of non-fatty milk-solids, and shall further take into account the extent to which the milk-fat may exceed 3.25 per cent. 111. That the artificial thickening of cream by any addition of gelatin or other substance shall raise a presumption that the cream is not genuine. IV. That any skimmed or separated milk in which the total milk-solids are less than 9 per cent. shall be deemed to be so deficient in normal constituents as to raise the presumption, until the contrary is proved, that it has been mixed with water.V. That any condensed milk (other than that labelled (‘ machine-skimmed milk” or “ekimmed milk,” in conformity with Section 11 of the Food and Drugs Act, 1899) in which either the amount of milk-fat is less than 10 per cent., or the amount of non-fatty milk-solids is less than 25 per cent., shall be deemed to be so deficient in some of the normal con- stituents of milk as to raise the presumption, until the contrary is proved, that it is not genuine. 115. The Committee beg further to submit the following expressions of opinion (a) That it is desirable to call the attention of those engaged in the administra- tion of the Food and Drugs Acts to the necessity of adopting effective measures to prevent any addition of water, separated or condensed milk, or other extraneous matter, for the purpose of reducing the quality of genuine milk to any limits fixed by regulation of the Board of Agriculture.( b ) That it is desirable that steps should be taken with the view of identifying or ‘‘ ear-marking ’’ separated milk by the addition of some suitable and innocuous substance, and by the adoption of procedure similar to that provided by Section 7 of the Food and Drugs Act, 1899, in regard to margarine. (c) That it is desirable that, so far as may be found practicable, the procedure adopted in collecting, forwarding, and retaining pending examination, samples of milk (including condensed milkj and cream under the Food and Drugs Acts should be uniform. (d) That it is desirable that, so far as may be found practicable, the methods of analysis used in the examination of samples of milk (including condensed milk) or cream taken under the Food and Drugs Acts should be uniform.(e) That it is desirable in the case of condensed milk (other than that labelled “ machine skimmed milk ” or ‘‘ skimmed milk,” in conformity with Section 11 of the Food and Drugs Act, lS99), that the label should state on points raised before them in evidence :THE ANALYST. 101 the amount of dilution required to make the proportion of milk-fat equal to that found in uncondensed milk containing not less than 3.25 per cent. of milk-f at. (f) That it is desirable in the case of condensed whole milk to limit, and in the case of condensed machine-skimmed milk, to exclude, the addition of sugar. ( 9 ) That the official standardizing of the measuring vessels commercially used in the testing of milk is desirable.Mr. S. W. Farmer, though he signs the Report generally, makes a reservation, as stated, in regard to “seasonal limits.” He holds that 12 per cent. of total solids is too low for six months of the year, and that 3-25 per cent. of fat is too high for the spring months. He would like to see seasonal limits of 3 per cent. of fat and 8.5 per cent. of non-fatty solids for March, April, May and June, and 3.25 per cent. of fat and 8-5 per cent. of non-fatty solids for the rest of the year. Mr. George Barham, in his minority report, differs entirely from his colleagues on the main points regarding whole milk. He would advocate a limit of total milk- solids of 11-75 per cent., with 3 per cent. of fat in the months of July to February inclusive, lowered to 2.75 per cent. of fat in the months of March to June inclusive, with a limit of 8-5 per cent. of non-fatty solids, in both cases alike. I n the case of skimmed or separated milk, Mr. Barham recommends a limit of 8.75 per cent. total solids instead of the 9 per cent. recommended in the majority report. The Report, price 74d., can be obtained from Messrs. Eyre and dpottiswoode, East Harding Street, Fleet Street, E.C. ; or other Government publishers; as also the Minutes of Evidence, Appendices, etc., price 3s. 8d.