60 THE ANALYST. REPORT OF THE ROYAL COMMISSION ON ARSENICAL POISONING I N FOOD. THE final Report of the Royal Commission which was appointed in February, 1901, to inquire into the subject of arsenical poisoning from the consumption of beer and other articles of food or drink was issued last month, and constitutes a document of the highest interest and importance. The members of the Royal Commission were tho Right Ron. Lord Kelvin, G.C.V.O., D.C.L., F.R.S. (Chairman) ; the Right Hon. Sir William Hart Dyke, Bart.,THE ANALYST. 61 M.P.; Professor T. E. Thorpe, C.B., LL.D., F.R.S., Principal Chemist of the Govern- ment Laboratories ; Mr. H. Cosmo Bonsor ; Sir William s. Church, Bart., M.D., F.R.C.P. ; and Dr. B. A. Whitelegge, F.R.C.P. ; with Dr. G. S. Buchanan, of the Local Government Board, as Secretary.The Commission explain that in the Report they use for convenience the general term LLfood” to include also articles of drink, and observe that where quantities of arsenic are stated the figures given refer to arsenic reckoned as arsenious oxide. The Report is signed by 911 the members of the Commission, but there is a memorandum by Dr. Thorpe, in which he explains his reason for dissenting from the views expressed by his colleagues as to the composition of the suggested “ Board of Reference.” The Report is divided for the sake of clearness into eight sections, the first of which deals with the epidemic of arsenical poisoning which occurred in the North of England in 1900, and contains some very important observations regarding the medical and public health aspects of the evidence given in connection with arsenic in beer and food.Part 11. deals with the disease known as ‘‘ beri-beri,” the information collected by the Commission tending to negative the idea that there is any essential connec- tion between that disease and the ingestion of arsenically contaminated food. In Part I. the causation of the 1900 epidemic is briefly discussed, and the steps taken to check the outbreak are reviewed. As showing the extent of the epidemic, the statement that the number of persons who suffered was certainly 6,000, and probably very considerably greater, is interesting. Seventy deaths were certified as having been caused by arsenical poisoning, but, as the Commission remark, I t is evident that deaths thus certified do not represent the total number of cases in which death resulted from or was accelerated by poisoning due to arsenic in beer.” The facts in connection with the minor outbreak of arsenical poisoning which occurred in Halifax in 1902 are next recounted.This epidemic was of especial interest, since the incriminated beer (some of which contained as much as & grain arsenic per gallon) was proved in many instances to have been brewed from malt alone. Analysis of the malt, which had been dried over local gas coke, revealed contamination to the extent of grain per pound in one case, and demonstrated in a striking manner the need for constant care and watchfulness in the malthouse. Many highly interesting observations in reference to the therapeutics of arsenic are to be found in this section.I t also contains the conclusions of the Commission as to the cumulative or non-cumulative character of this poison. “From the clinical data obtained it would appear that arsenic can only be termed a non-cumulative poison in a restricted and comparative sense, this element having been detected in the excretion in one exceptional case fifty-nine days after the ingestion of arsenical beer had ceased.” The excretion of arsenic by hair appeared to be of such special interest to the Commission that they instituted experiments which showed that the hair of male patients who had been taking about & grain of arsenic daily contained as much as + to In concluding this section the Commission refer to the importance of excluding small quantities of arsenic from food and drink, pointing out that this question is of greater importance than might at first sight be They say : grain of arsenic per pound.62 THE ANALYST.supposed, and calls for more attention than it has hitherto received. They adhere, in fact, to the view expressed in the first Report that it would be unwise for them to express an opinion that any quantity of arsenic, however small, is to be regarded as admissible in any articles of food. Part 111. deals with the question of testing for arsenic in food and substances used in the preparation or manufacture of food. The Commission, after referring to the value of the large amount of work on the subject which had been undertaken by individual chemists and to the reports issued by the Committee appointed by the Manchester Brewers’ Association and by the Joint Committee appointed by the Societies of Chemical Industry and Public Analysts, proceed to review the informa- tion thus obtained.As the conclusions of the Committee on this matter are of such interest to analysts generally, we deal somewhat fully with this portion of the Report. The information obtained by the Commission is reviewed under three headings : Estimation of Arsenic by comparison of Mirrors obtained by the Marsh-Berzelius Method with Zinc and Acid ; Estimation by comparison of Mirrors obtained Electro- lytically ; Estimation by other Quantitative Methods. COMPARISON OF MIRRORS OBTAINED BY THE MARSH-BERZELIUS METHOD. The evidence shows that it is now recognised that a satisfactory estimation of the arsenic in a given substance can be made by comparing mirrors obtained by the Marsh-Berzelius method, after the substance examined has been subjected to appro- priate treatment, by which any arsenic present is obtained in a solution suitable for the proper application of the test.Attention is called to the various causes which may operate against the accuracy of this process, but chemists are now in general agreement as to the main sources of error, and have but little difficulty in avoiding them. The Committee remark that they do not attempt to pronounce for or against particular modifications of the Marsh-Berzelius method which are preferred by one or another analyst. ( 6 We are satisfied that careful analysts who estimate arsenic by this method can obtain results sufficiently exact and comparable for practical purposes, although the details of their procedures may differ.Were it possible to secure for the future the uniform adoption by analysts of one and the same method with the same detail in all respects, the determinations would become still more closely comparable, with obvious advantage. The work of the committees and chemists to which we have above referred, and in particular the important recommendations of the Board of Inland Revenue Departmental Committee as to tests for arsenic in various sub- stances used in the preparation of beer, materially advance this object, but do not lead to the conclusion that at this stage any single detailed routine can be said to be applicable to all cases without exception.” It is pointed out that as regards detection of arsenic by the above method the evidence shows that when various substances are taken in quantities which have been found practically convenient, the presence of arsenic will be detected when in amounts well below --inn grain per pound, or (in the case of a liquid) well below & grain per gallon.They say :THE ANALYST. 63 The Commissioners recognise that the personal equation is of some importance in connection with the carrying out of this test, but they point out that the differences likely to be met with between careful and experienced operators would be so slight a8 to be practically negligible, and that in particular instances, where close approxima- tion is desired, the difficulty can be met by making more than one estimation, or, if need be, by repeating the experiment with a solution corresponding to a larger or smaller amount of the substance.Referring to the various forms of preliminary treatment which may be applied to different substances prior to the actual estimation by the Marsh-Berzelius method, the Commissioners remark that in the case of unground malt and a few other sub- stances a satisfactory estimation can be made without the destruction of organic matter, but that in such cases it is desirable that comparison should be made with standards prepared by the addition of known quantities of arsenious oxide to arsenic- free specimens of the material examined. In the case of organic substances which are liable to cause frothing, or in which the arsenic may possibly exist in the form of an organic compound, destruction of the organic matter by an “acid” or by a ‘‘ basic ” method is necessary, and in the case of brewers’ worts it is recommended to effect the destruction in all cases.“Several chemists who have given close attention to the subject prefer to destroy the organic matter in beer as a matter of routine before employing the Marsh- Berzelius test ; and the Departmental Committee of the Board of Inland Revenue also recommend this course. It appears to us that this plan should be uniformly adopted. ” I n the examination of fuel it is recommended either to employ the method of burning the fuel with lime or other base, or to adopt the process recently recom- mended by the Board of Inland Revenue Committee (ANALYST, vol.xxviii., 344). The electrolytic method recently recommended by the above Committee (ANALYST, vol. xxviii., 349) is also referred to, and some of the’ advantages which it appears to possess over the zinc method are enumerated. Other quantitative methods than the Marsh-Berzelius method are briefly referred to, but in view of the general use by analysts of the latter process, and to which such precision has been given by the work of the last few years, chemists are exhorted to acquaint themselves as to the extent to which their determinations correspond with or differ from those made by a comparison of mirrors. Part IV. deals with the various ways in which faods are liable to become con- taminated by arsenic.Among the principal ingredients of food or substances used in the preparation of food which are liable to contain arsenic, and which therefore ought to receive the special attention of the food chemist, the following are dealt with : sulphuric acid, hydrochloric acid, glucose, invert sugar, glycerine, colouring matters, caramel, phosphoric acid, phosphates, borates, and boric, tartaric and citric acids. Beer ‘‘ regenerators,” hardening materials, yeast foods, and other preparations employed by brewers are also referred to. The liability of malt. to be seriously contaminated by arsenic, whioh had been so amply demonstrated to the members of the Commission, and the difficulty of ex- Speaking of beer, the Commissioners remark :64 THE ANALYST. cluding small quantities of that element during manufacture, cause this food material to assume far greater importance than those above enumerated, and it is consequently dealt with at some length in the Report.The precautiona which maltsters should adopt in regard to the selection of fuel, the cleansing of kilns, and the screening and brushing of malt, are clearly set forth, and the Commission report to the effect that : ‘( All our evidence goes to show that it is now commercially practicable to produce malt which either may be considered free from arsenic, or in which the amount of arsenic present is certainly less than grain per pound (0.57 parts per million), and that most of the malt prepared during the past two years has been of this c haract er. ” The following finished foods, in the order in which they appear in the Report, are mentioned as being lisble to arsenical contamination through the use of the above ingredients or in other ways, in the absence of sufficient precautions : beer, golden syrup and treacle, jams, artificial honey, sweets and other foods containing glucose, vinegar, Demerara sugar (rarely), and food preparations made from malt and yeast.Foods containing colouring matters or preservatives may also, of course, contain small quantities of arsenic derived from those substances. Gelatine and liquorice are mentioned as food substances liable to be contaminated, and two samples of dried chicory contained about & grain per pound of arsenic. Part V. deals with the precautions which should be taken by manufacturers to exclude arsenic from foods, and is deserving of the most careful study by all who are engaged in the manufacture of food products.Reference is made in this section to such of the above-named substances as are also included in the British Pharmacopoeia. The Report says : ‘‘ At present the tests for arsenic which the British Pharmacopceia directs to be employed are qualitative, and the quantity of substance to which the qualitative tests are to be applied is in nearly every case undefined. The Pharmacopceial Committee of the General Medical Council has now under consideration the question of revising the Pharmacopoeia1 tests for arsenic, with the objeot of giving them a quantitative value, and of adding to the list of drugs which are required to be tested for arsenic.” Parts VI.and VII., which may be considered together, deal with the present means of official control over purity of food in relation to arsenic, and recommenda- tions as to improvements in official control over the purity of food, I t is pointed out that at present, save in a few special cases, the control which can be exercised over manufacturers of food becomes available only after the manufacture of the food is completed and it is on sale to the public. In this connection the existing Sale of Food and Drugs Acts come in for a considerable amount of discussion, and attention is directed to tne fact that for reasons well known prosecutions under Section 3 of the ,1875 Act are comparatively seldom instituted, and that in practice nearly all prosecutions are taken under Section 6, and the Commissioners remark : ‘‘ Even in the case of foods contaminated by arsenic in such ways as we have described in Part IV.of this Report, it would appear that a prosecution would in most instances have greater chance of success if taken under Section 6, and this view was held almost wiihout exception by the local authoritiee which decided to institute prosecu- tions with regard to arsenical beer in consequence of the 1900 epidemic.”THE ANALYST. 65 The evidence which was presented to the Commiesion by various official witnesses showed that the Sale of Food and Drugs Acts as at present interpreted and administered are unsatisfactory for the purpose of protecting the consumer against arsenic or other deleterious substances in food, partly on account of the difficulties involved in the question of warranty, and partly because the authorities have no means of knowing what particular foods are most liable to contain deleterious sub- stances.The Commissioners remark : ‘‘ As a rule, Public Analysts receive samples in order that they may pronounce upon their genuineness or otherwise, knowing nothing of the local circumstances which led to their being taken, of their origin, or of the reasons for sending them. The term ‘genuine’ in this sense means that the analyst has not detected such objectionable substances ES he has considered it necessary to look for in the sample submitted to him. Obviously, the value of the statement that a sample is ‘ genuine ’ depends upon the extent to which the analyst has means of knowing what are the objectionable substances which it is liable to contain.I n present circumstances he has not sufficient information on this point. Different analysts may thus pronounce upon the genuineness of identical samples on widely different data.” It is also pointed out that ‘‘ the application of the Sale of Food and Drugs Acts to prevention of contamination of foods by deleterious substances iR materially hindered by want of an official authority with the duty of dealing with the various medical, chemical, and technical questions involved,” and that the absence of official standards also militates against the efficiency of the existing Acts. After some reference to the Public Health Acts, the Report of the Commission proceeds to deal with several important ‘recommendations as to improvements in official control over the purity of food, and the necessity for more extended administration by the Local Government Board is referred to.I t is recommended that to this end the Local Government Board should have the assistance of a special officer, with suitable scientific knowledge,” who should be in relation with the Government Laboratory, and who would be able to institute the necessary chemical inquiries, and obtain, from various sources, such information as would in turn enable the Board to advise and direct the work of local authorities in the matter of securing the greater purity of food supplies. The Commissioners state that they are of opinion that official standards must be prescribed if the Sale of Food and Drugs Acts are to be satis- factorily applied to control the purity of food, and for reasons given they prefer to term these ‘‘ standards for the purpose of the Sale of Food and Drugs Acts ” rather than “ standards of purity.” I t is considered that the Local Government Board (under advice as indicated above) should be the authority to prescribe, and from time to time to vary, standards for the purpose of the Sale of Food and Drugs Acts.The Commission are of opinion that a Board or Court of Reference, such as has been recommended by the Committees on Food Products Adulteration and on Preserva- tives and Colouring Matterg in Foods, should be established. They further express the opinion that such should not be an administrative but a consultative Board, available on the application of the Government Department concerned to pronounce on specific points which are specially referred to them.The responsibility of manu- facturers or intermediate vendors under the existing Acts is referred to, and the66 THE ANALYST. Report says : ‘‘ If, in a prosecution instituted under the Sale of Food and Drugs Acts, it is-alleged by defendent A that the article was sold in the condition in which it was supplied to him by B (e.g., the manufacturer, importer, or giver of warranty), or that the contamination is due to an ingredient supplied by C, it should be possible for A to attach B (or C, as the cage may be) to the prosecution. The sama principle should apply to the person thus associated in the defence, if he in his turn alleges that a third party is responsible, by breach of warranty or otherwise, for the adultera- tion or contamination of the final product.” The last paragraph of the Report deals with the proportions of arsenic in food which would constitute an Gffence under the Sale of Food and Drugs Acts, and is as follows : ‘‘ Pending the establishment 0: oflicial standards in respect of arsenic under the Sale of Food and Drugs Acts, the evidence we have received fully justifies us in pro- nouncing certain quantities of arsenic in beer and in other foods as liable to be deleterious, and at the samo time capable of exclusion, with comparative ease, by the meful manufaoturer.In our view, it would be entirely proper that penalties should be imposed under the Sale of Food and Drugs Acts upon any vendor of beer or any othor liquid food, or of m y liquid entering into the composition of food, if that liquid is shown by sn adequate test to contain &$h of a grain or more of arsenic in the gallan; and with regard to solid food-no matter whether it is habitually con- sumed in large or in small quantities, or whether it is taken by itself (like golden syrup) or mixed with water or other substances (like chicory or ‘carnos’)-if the substance is shown by an adequate test to contain grain of arsenic or more in the pound.” In this final Report there is a memorandum by Dr.Thorpe, who differs from his colleagues as to the composition of the suggested Board of Reference. Dr. Thorpe says : ‘( I venture to think, therefore, that instead of creating a permanent committee consisting of a small number of scientific men, as the authority to prescribe the standardswhich should be fixed for the purposesof the Sale of Food and Drugs Acts, it would be preferable to follow the procedure of the Board of Agriculture, and to entrust the consideration of the propriety of fixing a, standard, or stmdards, in the case of particular groups of allied substances, to specially constituted committees in which manufacturers and technical experts in the trade concerned were represented. Considering the very large and legitimate commercial interests involved, I am of opinion that no other course would be satisfactory.” The Report may be obtained from Messrs. Eyre and Spottiswoode, of London ; Messrs. Oliver and Boyd, of Edinburgh ; or Mr. E. Ponsonby, of Dublin ; and is issued at the price of Qd. The two volumes of evidence are published at 49. and 3s. l l d .