THE ANALYST. AUGUST 1884. RECOGNISING the great interest felt by all analysts in the Conference upon the gubject of 6‘ Food Adulteration and Analysis,” held the week before last at the Health Exhibition, we have gone to the expense of lsecuring a verbtttirvb shorthand report of the proceedingg. We have made no attempt to in any way summarise the remarks of the speakers or to suppress such portions of the discussion as do not coincide with our views merely referring to them as ‘( flippant ” or loose ’’ remarks (which has been done by certain special journds), but we give the whole as actually spoken both for and against the present state of the Iaw. I t not being desirabh that the sizg of any particular volume of the ANALYST should be increased and placed out of uniformity with past years we have to bring such a mss of matter within reasonable limits printed %he whole in smaller type than usual Even then it has been found impossible to include the whole in one number and the remainder of the second day’s prooeedingg will be given in our September nuiber when we hope there will be space enough to finish the whoh The importance of publishing as muchaspossible th3 month must be our excuse for omitting all legal repork from the present number of the ANALYST.PROCEEDINGS OF THE CONFERENCE ON FOOD ADULTERATION AND ANALYSIS BELD AT THE IN!I!ERNATIONAL HEALTH EXHIBITION ON‘ 14~x1 JULY 1884. THX PRESIDENT (Dr Odling) opened the Conference and said The Executive Committee had invited the Institute of Chemistry over which I have the honour to preside to hold a Conference on the important subject of the adulteration of food and the means of analysis of food.We hope on a subject of this kind to which so much attention has been paid on the part of so many eminently qualified to treat the question that a discussion of considerable interest may arise and that sbme good in the way of increase of knoyledge as to the points of difficulty may be arrived at. We have the benefit of the presence and coioperation of a considerable number of gentlemen who occupy the important position of public analysts and we hope from them to derive a considerable amount of information bearing on the subject and in the undertaking we are fortunate in having the services of Dr Bell .of the Laboratory of Somerset House who has taken the trouble to prepare a paper taking the subject all round in its general bearings.He then called upon Dr. Bell w h delivered the following address :-FOOD ADULTERATION AND ANALYSIS. ADULTBRATXON. in its widest scnIse may be described as the act of debasing articles €or pecuniary profit by intentionally atlding thereto an inferior substance or by taking therefrom some valuable constituent ; and it may also be said to include the falsifkation of inferior articles by imparting to them the known appearance of commodities of superior quality. The evils of adulteration may be viewed either from a sanitary moral or pecuniary standpoint, and it is no doubt chiefly in its relation to the health of the people that the subject of Food Adulteration and Analysis has been chosen for B Conference in connection with this Exhibition.Of the sanitary evils of the adulteration of food there cannot be the faintest doubt and even on tbis ground alone the practice merits the severest condemnation. This is the case when the substance added merely reduces the nutritive value or characteristic property of the food but the offeme becomes highly criminal when the adulterant also possesses properties injurious to health. By Dr. JAMES I~EI~L F.R.S 134 THE ANALYST. The moral aspect of this question should never be lost sight of. No man can continuously practise deception without losing self.respect and also when detected and exposed the respect of his fellow-citizens. Moreover in such circumstances a feeling of uncertainty on the pftrt of the buyer is created and his first idea on the receipt of a commodity of somewhat lower quality than usual is that it must be adulterated.The honest vendor thus shares with the dishonest one the general penalty of suspicion and the transactions of nearly all dealers in articles of food are viewed with distrust. But it is from the pecuniary standpoint that the question is most often viewed by the general public for the primary cause of adulteration is a desire for unjust gain,. to be obtained either at the expense of consumers or by taking unfair advantage of competitors in trade. If the adulterated article is sold at the ordinary price of the genuine commodity the customer is robbed of the amount represented by the diminished value ; whereas if it be sold as genuine, though at a proportionate reduction in price the unfair competition tends either to seriously injure their honestly-disposed rivals in trade or what is but too often the case to drive them into a similar course.Attempts have sometimes been made to estimate roughly the amount of pecuniary loss suffered by consumers owing to the adulteration of different articles of food but for my part I have never been able t o see that any reliable data were obtainable upon which to form even the rudest approximate estimate. The practice of adulteration is by no means of modern date but has existed more or less from time immemorial. There is evidence that i t was practised by the Greeks and Romans and it has probably beeii co-existent with the development of commerce, The earliest enactments in this country in reference t o food appear to have had Q much wider scope than those of recent years for they embraced the quality as well as the genuineness of the article and dealers in foods or drinks which horn whatever cause were considered as unwholesome, were fined once or oftener and then if found incorrigible were condemned to bodily punishment.The first enactment on the Statute Book is the 66 Henry III. cap 6 passed in 1266. Under this and subsequent statutes or 4L Assizes,” the baker was to be purifshecl if he sold bread light in weight, or made from unsound wheat or a t too high a price in relation to that of wheat ; the brewer if he was not sufficiently liberal with his malt in proportion to the price of barley ; the beer-retailer if he sold ale drugged or short in measure ; the vintner if his wine was drugged corrupted or unwhole-some ; and the butcher if he sold diseased meat.When we consider the difficulty which at the present time we experience even with increased knowledge and appliances in suppressing adulteration it is not to be wondered at that the machinery of those days failed to put an end to the evils complained of, With the exception of one or two Acts relating to the adulteration of bread all the legislation upon articles of food from the time of George I. to the year 1860 had reference to the protection of the revenue and therefore only indirectly guarded the health or pocket of the consumer. The Aots within this period related principally to tea coffee beer and porter ; and if we are to place any reliance upon the words of an Act of Parliament the adulteration of tea a hundred years ago must have attained very alarming proportions.The Act 17 Geo. III. cap. 11 states that great quantities of sloe leaves and leaves of ash elder and other trees and shrubs were then being manufactured and sold in imitation of tea to the injury and destruction of great quantities of timber woods and under woods. In the year 1861 there was considerable agitation amongst planters and others interested in the production and sale of caffee in consequence of the falling off in the consumption of that article caused by its wholesale admixture as permitted by Treasury Minute with chicory. Petitions wero presented to both Houses of Parliament on the subject ’and it was perhaps the general attention directed at that time t o this matter which induced the proprietors of the Lancet to perform a public service of the highest value.In 1861 and several following years at their own expense they instituted an extensive inquiry into the character of the food drink and drugs sold in London and engaged.chemica1 and microscopical analysts for that purpose. The results showed that adulteration prevailed t o an alarming extent and that in many cases the adulterants were of a nature highly injurious to health. The Editor of the Lawet showed his confidence in the analysts employed by publishing in that journal the results of the analyses whether favourable or otherwise together with the name and address of the vendor. The increased public attention thus caused resulted in an inquiry by a Select Committee of the House of Commons in 1856 which reported that adulteration of food drink and drugs was very prevalent and that some of the adulterants used were of a poisonous nature.Following upon that report and as a consequence thereof the first general Act in thiscountry was passed in the year 1860. This Act may have exercised to some extent a deterrent effect but beyond this the practical outcome of it was but small for the appointment of analysts was permissive and the obtaining of samples for analysis was left to private purchasers. Another Act was passed in 1872 extending the right of appointing analysts to boroughs having separate police establishments but still left such appointments optional. A most important provision, however was made for the purchase of samples by local officials and the right was given to private purchasers to have samples analysed on payment; of a small fee.The adoption of the Acts of 1860 and 1872 was by no means general but was principally oonfined to London and the large towns ; and even where adopted the action taken was often of a vary restricted character. The prosecutions which ensued however were sufficiently numerous to cause a general outcry from tradesmen about alleged miscarriages of justice ; and in answer to petitions from most of the large towns the Government decided to appoint another Select Committee of the House o THE ANALYST. 135 clommons to inquire into the worlding of these Acts. !Eis Committee reported that while the Acts had done much good they had likewise done considerable injury as many heavy and undeserved penalties had been inflicted upon respectable tradesmen and that such injury had arisen partly from the want of a clear understanding as to what constitutes adulteration, and partly from the conflicting opinions and inexperience of the analysts employed some of whom appeared to have evinced a great want of discretion.I t was recommended that the Acts of 1860 and 1872 should be repealed and that a new extended and compulsory Act should be substituted for them. The chief amendments suggested were the inclusion of the fraudulent abstraction of an important property of any commodity such as the removal of cream from milk as a punishable offence j the examination of tea on importation ; better regulations for obtaining samples, and for securing the appointment of qualified food analysts.To meet’ an important waat provision was also made for obtaining an independent analysis in case of dispute. A great improvement had evidently taken place since the previous Parliamentary Committee had sat in 1866 especially in regard to the deleterious nature of adulterants.used for this Committee concluded their Report by expressing their belief that it will afford some consolation to the public that in the matter of adulteration they are ol7tsated rather thanpoisolzed; and that if deleterious substances are occasionally used for the purposes of adulteration they are used in such minute quantities as to be comparatively harmless. Further as a matter of policy they pointed out that they did not consider that Parliament desired needlessly to hamper or fetter trade still less to interfere between the buyer and seller with the view of regulating prices or attempting to assist the consumer in ascertaining the real money value of any marketable commodity.Upon the lines indicated in this Report was framed the Bill which passed into law as the Sale of Food and Drugs Act 1876 and which is the Act now in force though amended in some respects by the Sale of Food and Drugs Amendment Act 1879. I shall now pass on to consider lst the object of these Acts ; 2nd) the machinery proyided for attaining that object ; 3rd how far the Acts have succeeded ; and Pth analysis in relation to adulteration, The title of the Act of 1876 states that it is 4 4 to make better provision for the Sale of Food and Drugs in a pure state.” Although expressly intended to suppress adulteration in food drink and drugs the word “ adultwant ” or ‘‘ adulteration ” does not occur in any of the clauses for the reason, I believe that no definition of these terms could be framed to meet all practical requirements.The sale of mixtures is freely allowed provided that the nature of the commodity sold is brought to the notice of the purchaser before the sale is completed so that if necessary it may be declined and that no ingredient has been added so as to render the article injurious to health. The fundamental idea of the Act is found in section 6 which enacts that 6c no person shall sell to the prejudice of the purchaser any article of food or any drug which is not of the nature substance, and quality of the article demanded by such purchaser.” Here is a clause capable of a very wide definition but I think the spirit of the section is fairly expressed by Mr.Justice Mellor in delivering judgment in the Appeal Case *of Hoyle v. Hitohman when he says 4c The offence intended to be prevented by the Act was the fraudulent sale of articles adulterated by the admixture of foreign substances which would necessarily be to the prejudice of the purchaser and those words were inserted only to require that such adulteration should be shown to have been made ; ’) and further if the purchaser asks for a certain article and gets an article which by reason of some admixture of a foreign article is not of the nature or quality of the article he asks for he is necessarily prejudiced.” It would thus appear that for a purchaser to be prejudiced within the meaning of this clause it is necessary that the article sold should contain some admixture of a foreign substance not specified at the time of sale ; and therefore that the purchaser is not legally prejudiced when the article sold is of low quality but genuine.This view will be found confirmed in the twelfth Report of the Local Government Board in which it is stated that the Sale of Food and Drugs Acts are not designed to prevent the sale of poor articles but that of adulterated articles.” It has been urged that samples should be judged by those of average quality which the purchaser might reasonably expect to get : but this was evidently not the view of our legislators for Parliament deliberately abstained from fixing limits of quality for natural products whether in a raw or prepared state.I come now to the means provided for suppressing the adulteration of food. The Local Authorities of each city metropolitan district county or borough throughout the United Eingdom have now the power to appoint inspectors and duly qualified analysts for the purchase and analysis of samples and should they not appoint an analyst voluntarily they are required by the Act to do so when called upon by the Local Government Board in England or a corresponding authority in Scotland and Ireland. When any sample purchased according to the provisions of the Act is found adulterated the vendor can be summoned before a magistrate and on conviction fined in a sum not exceeding $20 where the adulteration is simply to the prejudice of the purchaser.When however the adulterant renders the article injurious to health the maximum penalty is $60 for a first offence and six months’ imprisonment subsequent convictions. On payment of a fee not exceeding 10s. 6d. a private purchaser may have any article analysed by the public analyst and if found adulterated the vendor if the provisions of the Act have been com-plied with may be prosecuted and fined as if the purchase had been made by the inspector. The requisite official machinery has not been provided in all places and the Local Government Board do not appear to have power to enforce the appointment of inspectors nor the purchase of a sufficient number of samples to ensure the efficient working of the Act.I find on inquiry that though analysts have been appointed for most places in England and Wales there were no fewer than sixty-three boroughs and three counties in which no mmples whateve 136 THE ANALYST. were analysed during the year 1883 and in many other places the number aualysed was very small, In Scotland out of thirtptwo counties only seven have yet appointed analysts and of these two have had no samples examined for six years while a third has only had one sample and a fourth only three samples analysed during the last three years. Of 167 royal and polit% boroughs thirty have appointed analysts thus showing only thirty-seven appointments for the whole of Scotland out of a possible total of 199 or about one in five.In striking contrast to Scotland is lraland where an analyst has been appointed for every place except one borough and one county, In considering some of the general results which have been obtained by the working of these Acts it would manifestly be unfair to institute a comparison between the years prior and subsequent to the Act of 1879 wbich laid down minimum strengths for spirits so I confine my statistics to the last three years for which returns have been issued by the Local Government Board. I regret that I have been unable to obtain complete returns for Scotland and Ireland so the following data for the years 1880, 1881 and 1882 showing the total number of samples analysed in each year with the percentage of samples reported as adulterated refer to England and Wales only..-Total Number of Percentage Eeported Year. Samples Analysed. Adulterated. 1880 17,673 15.7 1881 17,823 14% 1882 19,439 15.0 The percentage of samples found adulterated varies as might be expected somewhat from year to year in the various commodities ; but on the whole and so far as these returns show it is practically stationary. These are the only data available so far as I know ; and valuable as they are for comparison from year to year there are several reasons why they afford only a roughly approximate idea of the extent to which adulteration is pracbised in this country. On the one hand the samples are nearly all pur-chased by inspectors many of whom are personally known to the tradesmen,-the object for which the purchases are made being perfectly well understood ;-whilst some districts throughout the country are inadequately if at all represented.On the other hand a large number of samples are returned as adulterated where the amount is so small that no proceedings are instituted ; and to these may be added samples of which adequate notice of admixture had been given at the time of purchase and also samples of impure well-waters which are sometimes classed as adulterated. I may also mention that of 628 samples purchased bv private individuals in one year the percentage found adulterated was 26 as compared with only 14% per cent. in the samples purchased by the official inspectors during the same year ; but this may partly be accounted for by the fact that a private purchaser has generally good grounds for suspecting adulteration before going to the trouble and expense of having the article analysed.The small number of samples submitted for analysis by private purchasers has been more than once commented upon by the Local Government Board and Shows I think that the expense of the analysis together with the trouble involved in the event of a prosecution are more than private individuals are willing to bear Perhaps this is not surprising when it is considered how small an amount individually they have a t stake and how readily they can when dissatisfied change their tradesmen. The working classes especially who form the bulk of the population and are the greatest sufferers from adulteration can hardly be expected to take action on their own account if only by reason of the expense ; but there is often the further impediment of the analyst being many miles away and doubtless in such cases his name and address are not always generally known.It is much to be regretted that an evident unwillingness has been found on the part of some local authorities to bring these Adulteration Acts into operation. The Acts are practically a dead letter in some districts even where nominally complied with owing to the small number of samples purchased, or the conditions under which the purchases are made. In the twelfth Beport of the Local Government Board it is stated that in Bome cases (‘ scarcely any attempt is made t o conceal the official character of the buyers or the purpose for which they are buying ; ” and the Board add what must be perfectly obvious s6 that unless the samples obtained by the inspector are of the quality ordinarily sold to the public the object of the purchase is frustrated.” In some districts the local authorities have been much discouraged by the small fines imposed by the magistrates even when the offence has been committed more than once.There Can be little inducement for them to carry out these Acts energetically when they find that after going to ail the exfiense and trouble of the purchase and analysis of samples and taking the necessary legal proceedings against a fraudulent tradesman the heinousness of his offence is assessed by the magistrates a t such a trifling sum as cannot in any view be held to be a deterrent penalty but one readily covered by the illegitimate profits of a few days.The tendency in recent years has been to place increased discretionary power in the hands of magistrates. For many years prior to 1879 their discretion in matters of fines in Revenue cwes was limited to reducing penalties to not less than one-fourth of the amount named in the Act. BY the Summary Jurisdiction Act of 1879 however they were given full discretionary power in fist offences, but the former restriction remains in force for second and subsequent offences Some such regulation may be found desirable under the Sale of Food and Drugs Acts especially in cases where the vendor is the actual adulterator. In discussing the relation of analysis t o adulteration it is not my intention t o review the variou THE ANALYST.137 ~~ methods of analysis but merely to refer briefly to some of the analytical difficulties experienced in dealing with the subject. When the adulterant differs chemically or microscopically from the article to which it is added as when alum is added to flour or bread or wheat flour to mustQrd the detection of the’adulterant is only dependent,upon the skill and experience of the analyst. But when the adulterant is similar in character to or identical with one of the constituenh of the article to which it is added wc are met at the outset with a formidable obstacle in the fact that natural products of all kinds vary greatly both in composition and quality and the problem presented for solution is then whether lowness of quality is due to natural poverty or to adulteration, There are butters for instance so rich in quality that they would admit of a large addition of foreign fat and still yield analytical results within the limits of genuine but poor butter.Again, it is well known that the milk yielded by some cows is of so low a quality as not to be equal to that from other cows with a large proportion of added water. Further there are some teas which, regarded from whatever test of quality we may apply are so rich that they will bear a considerable admixture of partially exhausted tea-leaves and still yield results equal to those from other poorer, but yet genuine teas. This is the difficulty which more than all others of a scientific nature stands, and I fear will continue to stand in the way of the entire suppression of adulteration.Unfortunately the history of food analysis shows that this difficulty in dealing with natural products has been increased t o some extent by the adoption of different processes of analysis which, in the hands of various chemists have yielded results differing so materially as to lead to contrary opinions upon the same samplo. To my mind it is therefore most important that whatever analytical process is used it should yield ahsolute and not comparative results. There are however occasions on which differences of opinion between analysts may be expected to arise as €or instance when the microscope has to be depended upon for the detection and estimation o€ the adulterant. Any want of concord between analysts in respect to their estimate of the proportion of adulteration in such cases as the presence of barley-meal in oatmeal or rice flour in ground ginger should not be made too much of as the certain proof of admixture is the main thing to be desired and it can make but little difference whether the perdentage of the adulterant be returned say as I5 or 20 per cent.limits,” founded upon the analyses of samples of average quality should be laid down and legalised for natural products below which such products should be deemed to be not “of the nature substance or quality of the article demanded,” but the adoption of such 4c limits ” might lead to grave difficulties. It is the opinion of practical men that it would be unwise t o adopt any legislative measure with respect to limits of quality which would tend to discourage production and diminish the supply of any article of food.It would manifestly be an economic blunder if for instance in order to raise the quality of milk by one half of 1 per cent. on the non-fatty solids the actual production were to be diminished by 10 per cent. in quantity. Following these views it may be of interest to particularise some of the principal articles of food, and the results of the analyses of samples under the Adulteration Acts of 1875 and 1879. I have taken the data from the Local Government Board’s Reports founded upon Returns make by the Public Analysts and of which an able Summary for the five years 1878 to 1882 mill be found in a valuable Handbook on the Law of Adulteration,” by Thomas Herbert published by Knight and Go., of Fleet Street.- MiQL-RpJrinninrr wit& milk. WR find that. it differs frnm mnnt nther na.tiim.1 fnnd nrndiidx in th9.l: The judging of the quality of milk may therefore be considered to be largely dependent on analysis, and having regard to the facility with which it can be adulterated the public require a greater amount of assistance in order to secure a supply of genuine milk than t h y do in the case of almost any other article of food. I have little doubt that in course of time withi the increasing means of education the public will become more skilful in judging of the quality of milk and other com-modities and will be able frequently to detect those instances of gross adulteration which may now pass unobserved. The range of quality in the milks obtained from healthy and well-fed CQWS is very considerable.Taking the non-fatty solids of the milk as a criterion of value I have found in common with others that the percentage varies-with a few exceptions on either extreme-from 8.2 to 108 per cent. It is evident that amilk of the higher value might be subjected to a good deal of watering-about 25 per cent.-and still yield the results obtained from the poorer but still genuine milk. This opening to sophistication which the differences in the quality of milk permit is not less, but even exceeded in the case of bntter owing to the greater range in its quality a point I shall shortly have to notice. For a long time it was contended that cows which gave milk containing less than 9 per cent of non-fatty solids were either diseased or starved but this notion may now be said to be dispelled for the more the matter has bcen investigated the more has such a position been found untenablc.Milk yields very variable proportions of fat. The percentage is sometimes as low as 2.2 and occasionally rises to as high as 6. This great range of difference affords facilities in some instances for the abstraction of parc of the cream and unfortunately renders the analysis in such cases of but It is frequentIy urged that certai 1.38 THE ANALYST. little value in protecting the public against this species of fraud-a circumstance much to be regretted when the high value attached to the fat of milk is considered. As to the necessary groundwork of milk analysis chemists are aniversally agreed.The data sought for are the percentages of fat non-fatty solids and ash ; but in order that the results of one analyst may compare with those of another the processes employed for determining these data require to be uniform and the methods themselves must be such as will yield accurate results. As proceedings under the Adulteration Acts are of the nature of a criminal prosecution it is essential that the analysis should not indicate mere comparative results but that the constituents relied upon for forming an opinion should be expressed by those weights or percentages which shall set forth the true quantity inr &he substance analysed as absolutely as the most skilful analysis can provide. About 6,300 samples of milk are analysed yearly in England of which 20 per cent.are returned as adulterated. The offences are practically confined to addition of water and abstraction of cream, but occasionally preservativerj such as boric acid designed to prevent the milk from turning sour, have been found and also but still more rarely sugar and colouring matters. While admitting that in some districts the milk-sellers may be adequately sampled yet taking the country as a whale the total number of samples analysed appears to me to be insufficient to show to what extent adulteration is generally; practised or to act as an effective bar t o the practice. Buttecr.-The supply of good wholesome and genuine butter for the public use is a desideratum. Fortunately however in thia they are able in a great meaanre to become their own judges.They c a s readily distinguish between what is sweet and rancid and can discover a butter which is heavily loaded with salt and often detect the presence of an excemive amount of water. In fact the public can practically protect themselves against most forms of buttes adulteration except that arising from the admixture of foreign fat. Butter is another illustration of the difficulty with which chemists have to contend arising from the wide variation in the composition of the article in a pure state; and as in the case of milk it is essential that in order to avoid differences in results and contrary opinions the method of analysis adopted should be such as to effect a complete and accurate separation of what is termed the soluble and insoluble fatty acids. It is now generally admitted that the percentage of fixed fatty acids found in genuine butters varies from 85.6 to nearly 900 per cent, so that the addition of something like 40 per cent.of a carefully selected foreign fat to the richest butter would still leave the percentage of insoluble fatty acids within the range of a genuine butter. As in the case of milk chemists are agreed upon the lines to be followed for the determination of the genuineness of butter and differences can only arise from variations in processes followed for the attainment of the necessary data. About 1,200 samples of butter are analysed yearly of whit& 15 per cent. are reported against. The adulteration consists in the substitution or admixture of foreign fats and occasionally in the introduction of an excessive amount of water.In connection with this subject I may mention that the manufacture of artificial butter compounds from animsl and vegetable fats has in recent years attained enormous proportions in the United States of America. These compounds known as butterine oleomargarine suine, etc. are in the opinion of high authorities legitimate articles of commerce if sold under names which properly indicate their origin and composition. If manufactured in a cleanly manner from sound fats they are perfectly wholesome and afford the poor a cheap and useful mbstitute for butter especially during the winter months, when good butter is both scarce and dear I see however that the Legislature of the State of New York has at the instigation of the farming interest resolved to suppress the manufacture and sale of such compounds within the bounds of that State.This decision was based upon the evidence given in what is said to have been a very one-sided investigation and in which it was stated that such compounds contained deadly germs ; that the workmen engaged in their manufacture were subject to loathsome diseases; and that by their use the death-rate of New York had increased at an alarming pace. Putting aside such undoubtedly exaggerated statement8 it is highly probable that with the increased demand there may have been lesiJ care exercised in the manufacture than a t first and that in some cases impure or decomposed fats may have been used but these are grounds rather for sanitary supervision than for the suppression of the trade.6%8e8e.-It is considered that the consumer can in a great measure protect himself in his purchases of cheese. The range of prices plainly shows him the different qualities and he can exercise his judgment in selecting the kind best adapted to his taste and pocket. I am not aware of any instance in which an adulteration of cheese has been reported. Colouring matter is the only foreign ingredient employed in its manufacture but this is a necessity to satisfy the public taste as regards colour. The successful manufacture of factitious butter from animal and vegetable fats has naturallx suggested their substitution for milk fat in cheese but there is no evidence that '' butterine cheese has yet found its way into the English market When it does there are adequate chemical tests to distinguish it from the genuine article.BvmL-About 1,100 samples of bread are analysed annually of which on the average 6 per cent. are shown as adulterated. The principal adulterant is alum which was reported in one case a THE ANALYST. 139 being present to the almost incredible amount of 1,306 grains or nearly 3 ounces to the quartern loaf. I do not think it would be questioned that so large an addition of alum must be injurious to the health of the consumer. The amount usually added however is comparatively small being only about 30 to 40 grains in the 4-pound loaf and whether then injurious to health or not is a matter in dispute there being both chemists and medical men who take opposite views on this subject. When the objects for which alum is added are considered that it is either to enable unsound flour to be used, or to cause the bread to appear to have been made from better flour than has really been the case its use should be strongly deprecated and its presence treated as an adulteration.Tea.-The number of samples of tea analgsed by public analysts is small and the cases are very rare in which adulteration is reported. This no doubt in part arises from the scrutiny which tea undergoes on importation which has had the effect of discouraging in great measure the trade in adulterated teas, The manufacture in this country of spurious teas from the leaves of other pIants or from exhausted tea-leaves is extinct ; for the low price at which genuine tea can now be sold holds out but small induce-ment for the increased risk under the present adulteration Acts of manufacturing and selling a spurious article.The methods of analysis adopted for the detection of the adulteration of tea are fairly effective and the only form of sophistication which could be practised with any chance of success is the admixture by the Chinese of partially exhausted tea-leaves. Co$*ee.-About 1,280 samples of coffee are yearly analysed of which 18 per cent. are reported as adulterated. With rare exceptions the sole adulterant found is chicory which it may be mentioned, is the only substance that can legally be added to coffee without requiring the payment of a further tax in the form of a stamp duty. The adulterants of coffee all consist of vegetable matter and allowing that the analyst is acquainted with the structure of the different vegetable tissues their detection by the microscope becomes a matter of certainty, In connection with coffee it may be noticed and the remark applies equally to all substances on which a Revenue duty is imposed that the interests of the public are largely though indirectly pro-tected by the constant supervision and inspection which such commodities undergo either in their manufacture or sale so that before such articles in the adulterated state can come into the hands of the public analyst they must have evaded those safeguards which the restrictions of the Revenue Acts provide.That such a rksult is brought about receives confirmation from the fact that it is seldom that a prosecution arises under the Food and Drugs Act for the adulteration of a dutiable article with a marketable commodity not liable to duty.Spirits.-Whisky gin rum and brandy are the only articles under these Acts which are required to be sold at not less than a specified strength unless otherwise declared at the time of sale. These spirituous liquors are in a different position to natural products for being in all cases mixtures of manufactured spirit and water the relative proportions of which are readily ascertainable, it was not unreasonable for Parliament to fix a minimum proportion for the essential constituent alcohol (defined in terms of proof spirit) below which the retail purchaser was to be considered “prejudiced,” unless made aware of the fact at the time of sale. It is true that the percentage of alcohol is but one factor in determining the commercial value of spirits and that a purchaser may receive better value for money in a well-matured spirit below the minimum strength than if he were supplied with a less-matured article at or above that strength.The alcoholic value however is the only one which can be accurately estimated and about which therefore analysts may fairly be expected to agree. About 2,000 samples of spirits are annually analysed of which 25 per cent. are reported as adulterated but only in very isolated cases has any other adulterant than water been found. This is a striking refutation of the opinion so frequently expressed that most of the evils of spirit drinking are due to adulteration and no better illustration could be afforded of the frequency with which inferiority of quality is confounded with adulteration.On several occasions samples of whisky have been sent to me from districts where the people were said to be injuriously affected by drinking the spirit and I have never met with an adulterated sample but the spirit was invariably of a raw and immature character. The changes that take place in the maturing of spirit whereby it loses its fiery character and the deleterious traces of fuse1 oil become changed into comparatively harmless flavouring ethers are not well understood and it is impossible by any mode of analysis at present known to separate spirits into the two clearly defined classes of those which are new and deleterioys, and those which are sufficiently matured as to be harmless this being rendered all the more difficult by the common practice of blending spirits of various ages and flavours in order to get a mixture having a certain recognised character.In some measure to meet this difficulty an effort was made a few years ago by a well-known irish member of the House of Commons an effort which is now being renewed to move the legislature to enact that whisky before being sent out for consumption must have been kept in warehouse for a t least one year. This attempt however did not succeed through the trade difficulties which were found to beset such a plan. The obstacles in the way of controlling the quality or genuineness of brandy are even greater than in the case of whisky as its production is carried on outside this country and the practice of adding a certain proportion of plain spirit and a mixture of sugar and flavouring matter to real brandy has become fully recognised in the trade and is allowed for in the purchase and sale of this article 140 THE ANALYBT.-I___ This addition of saccharine matter has a marked tendency to obscure the naturally harsh character of brandy and to cause its coarse and immature nature to pass unnoticed by the public generally while whisky being free from sugar a t once appeals t o the palate in cases where the spirit is of a new or fiery character. That the circumstances indicated create formidable difficulties in the application of chemica* tests t o brandy suspected to contain added spirit is clearly evidenced from the fact that there does not appear to have been any successful prosecution under this headin connection with the Food and Drugs Act.BeePT.-This from its position as the national beverage of this country is of especial interest and importance in its relation t o analysis and adulteration. Prior to 1817 beer could be accurately and legally defined as a fermented beverage prepared from malt and hops but in that year sugar was allowed to be used. Fifteen years later namely in 18G2 the hop duty was abolished and revenue interference with the use of hop substitutes ceased ; then in 1880 the malt duty was removed and brewers were allowed by the Beer Act of that year t o use any materials whatever capable of being used in brewing. There is no legal limitation as to the strength or original gravity of beer nor as to the degree to which it shall be fermentcd or in other words the proportion of alcohol it shall contain It is therefore impossible to give a clear and concise definition of what beer ought legally to be The former definition and still popular idea that it is a fermented beverage prepared exclusively from malt and hops is neither supported by revenue law nor by present trade practice for there may now be legal beer without either one or the other or even without both.Under what circumstances then can a purchaser of beer be deemed to be prejudiced 1 The Local Government Board have stated that ‘( it would seem to follow ,from decisions in the High Court of Justice that a purchaser in demanding beer must be held to mean the article ordinarily sold under that name and that it would be to his prejudice to sell him at^ beer an article not of the nature, substance and quality of that ordinarily sold as such whether containing ingredients injurious to health or not.” It is not easy t o fix a basis or standard of quality for the article ordinarily sold as beer for it is my experience,’ as well as that of other analysts that even in the same town the money value of beer sold under the same name and at the same price differs by as much as 50 per cent.from whatever point of view its value may be Considered. Suggestions have been made that as in the case of spirits minimum limits of strength based upon original gravity should be laid down by Parliament for the several well-recognised sorts of beer ; but there would be many objections to such a course, more especially where the value of the beer depends more upon its character or ffavour than upon its strength.An Association has been formed to cause the ingredients from which the beer has been made to be declared but I fear that those who expect analysts to be able to prove or disprove the truth of such declarations rather overrate the present capabilities of chemical science. A popular notion has long prevailed that no article is more manipulated than beer and it is therefore satisfactory t o find that there have been comparatively few prosecutions for the adulteration of beer and so far as T know the only adulterant found has been common salt. Now the amount of common salt naturally present in beers varies widely some of those containing the largest proportions being held by the public in high repute.As salt is added as an antiseptic and really increases the keeping properties of some beers it has been contended that the public cannot have been much prejudiced in those cases where a small quantity has been added but where the total amount present is within the limits of a genuine beer held by them in high estimation. It was my intention t o discuss in detail several other subjects of interest including wine but it appeared to me that if I did so the paper would prove too lengthy and tedious for the opening of a Conference, I may say however that in most articles of food there has been a very great improvement in recent years as regards adulteration and that the gross and deleterious forms of sophistication which are stated to have been extensively carried on at one time are now practically abandoned.For example the only substances which are now found in cocoa are sugar and starch and in mustard flour and turmer85 and these additions are not considered as adulterants so long as the preparations are not sold as pure or unmixed articles. Again,in the manufacture of confectionery not only has the use of earthy substances been discontinued but the employment of pernicious colonring materials has practically disappeared and harmless vegetable colours are now almost universally employed. Even in pickles and preserved vegetables it is now rare to find the colour heightened by the addition of a salt of copper and the colour of cayenne pepper is no longer improved by the use of red lead, In fact in whatever direction we look the same improvement is observable judging from the Beports of the Public Analysts to the Local Government Board and the absence of prosecutions.Before concluding I desire to express my opXion that the machinery provided by the legislature for the suppression of adulteration is fairly efficient and only requires to be vigorously worked by the various local authorities in order to be productive of great good to the community. I trust that this Conference will be the means of stimulating the authorities to a more zealous administration of these Acts and particularly of directing their attention to the advisability of obtaining samples for analysis from every part of their district and with such precautions as will insure the purchase of articles in the state in which they are ordinarily supplied to the general publie.1 cannot conclude however without expressing my sense of the efficiency of the work which has been and is now being done by public analysts not onIy in their officiaI capacities but in regard t THE ANALYST. 141 their contributions to analytical science of which their works on bread milk and butter may be cited as well-known examples. It has been the least pleasant part of my duty to have to differ from them as sometimes they lmve differed among themselves at one time on actual results of analysis and at another on the deductions to be drawn from practically similar results but such instances should not affect the confidence with which the general ability and high services of public analysts ought to be regarded, The C~~AIRMAN after expressing on behalf of the audience their thanks and his own for Dr.Bell's very complete and interesting paper which was characterised by its fairness and impartiality on the subject which he had kindly consented to bring forward proceeded to say-I think moreover I may venture to express on behalf of this meeting,our cordial agreement on several of the statements which he has put forward and I think I may take it on myself to declare how very largely the public is indebted t o the labours of those many gentlemen who undertake so ably, the office of Public Analysts and how largely purely analytical chemistry has advanced in consequence. It is gratifying to hear from Dr.Bell,-that there has been so large an improvement in recent years in adulteration and that thc gross and deleterious forms of sophistication which are stated to have been so much carried on at one time are now abandoned; so far we may regard the Adulteration Acts as a succcss. We further feel I am sure with Dr. Bell that there cannot be the faintest doubt of the sanitary evils resulting from the adulteration of food, and accordingly in connection with this Health Exhibition we may congratulate ourselves on that means of adding to the public health which has resulted from the working of the Adulteration Acts. It will now be my province to invite your discussion on the very many points which will occur to any of us in reference t o the large number of topics introduced t o our notice by Dr.Bell. We admit that the Acts upon the whole work well-the question arises whether they might not be made to work betler ; whether they are not susceptible of amendment ; whether they do not in some points imperatively call for amendment If the matter before-us was nothing else than the repression of adulteration it is obviously true that the Acts might be very considerably amended in respect to their efficiency ; but there are other conditions and we cannot conceal from ourselves that, to some extent varying in extent Acts of this kind are more or less prejudicial to trade and invention. That is a point we have to guard against. We are all interested in the supply of pure and honest food; we are interested in not interfering with its abundant and cheap supply and with the improvements in the methods of production especially in those articles of food which are more or less of an artificial character.I fear if an adulteration Act had been in vigour years ago what he has told us as to beer would not then have been found to be quite so jn&. I say we have to regard on the one hand the desirability of securing wholesome and pure and honest food and at the same time of not interfering with the abundance of its supply or with the progress of improvement. Now with regard to these questions it is not €or me to express my opinion upon any point but rather to invite the expression of yours ; but I will say something as to the necessity of an amendment of the Acts, and to know how far the Act should or should not be altered in certain particulars-how far it may be necessary to amend it so as t o insure its general applicability.There are parts of the country where these Acts are not in really active working order. It appears that the Local Government Board have power to enforce the application of the Act so far as the appointment of analysts is concerned but not as regards inspectors or analyses of any or of a sufficiency of samples. Another point is how €ar is it necessary or desirable to amend the Act in such a way as to ensure the examina-tion of a sufficient number of samples. It apaears in many cases that although the Act is to a certain extent in force the number of samples is so "small that it can have no influence upon the character of the supply in the district. Another point is how far it is possible to secure that the articles submitted to the analysis of the public analyst are the actual articles which are being supplied to the public in that neighbourhood.Here of course the question comes in as to how far the duties of the inspector are interfered with by the knowledge of his person and office and how far i t would 'be advantageous to bring about the examination of a larger number of sqmples by private people. Another thing is the repressive effect of punishment-that there should Be some limit to the power of reduction of fines in the case of second or subsequent convictions as in Inland Bevenue cases. Another point which naturally suggests itself is how far there should be an increase or diminution in the stringency-for instance Dr.Bell has told us that beer is qualified only by this definition, that it must be the article ordinarily sold under that name and the question is whether matters should be left in that open state or if it be desirable to leave them so in regard to beer whether it would not be well to do so with regard to other articles; if for beer why not for butter cheese, etc.? Another question arises as to how far the use of chemical agents is allowable. We all know that many samples of beer contain bisulphate of lime and I am not aware that any beer-producer has ever been interfered with on that account yet milk dealers are soon interfered with when they use boracic acid As regards bread bitartrate of potash was introduced €ormerly and this has more recently been replaced by some of the hypophosphites of lime.Another point which I will put forward as a suggestion-how far the adulteration of human food restrictions can be extended so as to include food for cattle which is also an object of interest to us and how far the work of the public analyst might not be directed to certain articles of food such as syrups fruit essences many of which are neither more nor less than chemical compounds ; and again to mineral waters and on what terms and conditions. Another point and one of some delicacy is as to how far the mode of settling dwerences of opinion or diflferences of statement between analysts-how far that mode is altogether satisfactory ox how far it might be possible to subject it to some improvement. I I 142 THE ANALYST. mean the mode which is adopted of referring these matters to the Inland Revenue Chemical Department.This is a very unusual proceeding Generally the different chemists or doctors are placed one in face of the other in the witness-box and the judge and jury are left to decide between conflicting opinions. Occasionally some particular expert is called upon to act as a referee but only by the consent of both parties Then comes the important point raised by Dr. Bell as to the desirability or not of the fixation of staadards of quality in articles like milk and butter which are subject to great variations in their quality for a customer might be more prejudiced by buying an inferior genuine article than by buging a high quality article subjected to adulteration. A question therefore, will arise how far these inferior articles should be allowed and how far any regulation of this kind would limit the supply If as Dr.Bell has suggested a limit which would augment the non-fatty solids of milk by one half of one per cent would really reduce the quantity of the supply some ten per cent. then I think the proposition would scarcely meet with approval. Opinions however will differ as to whether or not it would have this effect; then how far would it affect the average result in the way of bringing down the higher quality milk to this lower standard, nevertheless it may have the effect of improving the general average. One more point is the difficulty of analyses by reason of the range of variation of the natural standard in certain products what should be the standard in milk and what in butter? We all know that very considerable differences of opinion have arisen and have led to discussion with regard to what should be the standard which should serve as a means of expressing the proportion of water added to any particular milk.Nevertheless it is cz very important point and with a little mutual tolerance we shall be enabled to discuss it here without any undue warmth. Then the modes of analysis-the meeting must decide as to that but we may discuss the desirability of obtaining results which are expressly designed to obtain exact percentages. Another point of considerable importance is that some of these adulterations are undoubtedly added with the object and with the result of improving as a marketable or eatable article the materials of food to which they are added ; for instance as in the case of bread we know that alum does add to the appearance of the loaf.The question therefore, arises as to how far may these qualities be obtained from some alteration in the method of production without the addition of alum. These are the chief' points which have occurred to my mind but the Conference and my colleagues here would be glad to hear the free expression of opinions by the gentlemen here present, so well able to express them, Dr. VOELCKER On the tender point of the sale of foods and drinks I venture to express the opinion that a very great deal of good would be done if the Adulteration Bill included the adultera-tion of cattle food. The public have no idea to what extent adulteration of cattle foods is systema-tically practised in England It is astonishing to foreigners when they come to England and are told of the extent to which they are adulterated.It is true that of late years owing to the energy dis-played by the Royal Agricultural Society of England (who have taken a very bold course in some cases and have published the names of the offenders) that the adulteration of cattle food has some-what diminished but still it is very largely practised now and I have no hesitation in saying that if five or six hundred specimens of linseed-cakes of a definite and specified character be taken leaving out the mixed cases which are professedly sold as mixed cakes a very large proportion would be found to be adulterated. In the same way food meal such as refuse from starch manufactories, Indian corn-flour etc.is frequently adulterated and a great deal of harm is done to the cattle who feed upon this as for instance by eating rice-meal adulterated with gypsum. Then again a great many cows are poisoned by cake which is adulterated with mustard-seed or rape-seed which grows in the fields ; there is no difficulty in obtaining pure linseed reasonably pure only containing about 5 per cent. of foreign matters. A few years ago there were a few mills who refused to grind pure linseed, but undoubtedly this has somewhat diminished. I will further confine myself to matters with which I am intimately acquainted. I have had a very large experience in these matters from my official con-nection which various societies and especially as the consulting chemist to the Royal Agricultural Society.I have been brought into close contact with all matters connected with agricultural produce-milk butter and cheese. I@ has been stated that it was a great advantage to fix a definite standard of quality for milk ; well if so why did you not fix it high enough and upon a reasonable and sound basis and not as it has been done on questionable analyses of the subject 1 The fact of the case is that the present standard adopted by public analysts is far too low and I venture to say that from half to three-quarters of all the milk sold in London and elsewhere is partially skimmed and not of the nature of the milk as furnished by the cow. A good deal of the cream is withdrawn and water is added.I have found as much as 8 or 9 per cent. of fine butter fat in good Alderney cows' milk and, of course this you would have to pay dear for ; but when it comes down to 5 per cent it is certainly partially skimmed and it is due to the fact that public analysts have more or less made known among those trading in milk that a certain low limit was fixed above which no action would be taken. The estimates hitherto made are far too low and this I believe is owing to the examination having been conducted on the imperfectly dried residue of milk the presence of the additional water rendering of course the result lower in proportion to the bulk and weight. The difficulty of fixing any standard is that milk is subject to such great variations-at certain times OP the year milk is naturally poorer in quality than in others; in spring for example,when the fresh vegetables contain a larger propor-tion of water whereas at this time of year the milk should naturally be richer from the greater maturity of the plants from which the cows derive their nourishment.Still with all these variations, I think we ought to fix upon a certain minimum and I cannot help thinking that 3 per cent. of pure butter fat and 8 per cent. of non-fatty residue would be more in accordance with the propriety o TBE ANALYST. 143 selling milk of fairly pure average quality. I have been told by dealers why should we furnish 3 per cent. of fatty residue when we can furnish less for the same price 1 and even if certain honest dealers sold milk of this standard they would be undersold and discouraged by the tnultitude of other dealers who are disposed to take advantage of the present state of the law.You may take it for granted that as a general rule milk dealers will not furnish better milk than they are obliged to do. With regard to cheese I do not altogether agree with what Dr. Bell says as to butterine cheese that it has not yet found its way into the market. I think there is a good deal in the market ; the exportation from America of oleo-margarine cheese is largely on the increase and there is something to be said for this oleo-margarine cheese. I have tasted excellent cheese of this kind and as long as it is sold for what it is I do not see any objection to such cheese. Some of the oleo-margarine is used in the manufacture of Dutch butters and there is probably a good deal exported every week to Holland which comes back again as the best Dutch butters to England.As long as the materials employed are of a wholesome character and palatable there can be no objection to their use. A good deal of cheese in England is unsaleable and if by the admixture of these materials it can be made a marketable Article no great harm is done and no great disadvantage is inflicted on the public; the whole thing is that it should be sold for what it is and not for what it is not. In conclusion perhaps I may be allowed to give a few words of caution to public analysts. They have it is evident done a great deal of good during the last few years. The adulteration of food has certainly greatly diminished and the exertions of public analysts to do their duty have been more and more recognised by those in authority ; therefore it is not altogether with the view of finding fault with them that I make the remark that perhaps a little caution would be a very desirable quality with some public analysts.They should not jump to the conclusion that an article is adulterated because a certain thing is present which has really nothing whatever to do with the partioular character of the article of food under examination. Only a few days ago-last week in fact-a sample of cream was submitted to me ; my impression was that starch, in the shape of thick starch paste might have been used. Iapplied the usual test and found some but thequantity was so small that I knew at once that starch had not been added for thepurpose of adultera-tion especially as under the microscope only an odd granule or two could be found.This turned out to be due to the cream having been strained through a new calico sieve and so some small quantity of starch had thus been introduced Agentleman sent me some milk not long since which he said gave a purple-coloured ring and he thought something dreadful had happened ; however under the microscope and subsequent chemical tests I readily found it was an aniline dye-here the milk had been passed through a red-coloured calico These were typical cases where a little care and inquiry showed that the articles were not really adulterated, A lady in the audience here expressed her wish to know whether $here was a society to enable poor people to have their food analysed also whether there is a public analyst for Ramsgate.The President said there was no society with that object in view but analyses could be obtained for the sum of 10s. Gd. j he added that there was a Public Analyst for Ramsgate and he resided in Canterbury, Dr. DUPBE public analyst said Public analysts have unfortunately very rarely the opportunity of bringing their case before the general public and I very gladly avail myself of the opportunity of stating the case from the analyst's point of view. I hope both manufacturers and dealers are present, and will give us their opinion on the opposite side. In the first place I take it adulteration has very much diminished more particularly in such articles as fall more generally under the Act-such as milk bread coffee and spirits-but the diminution is not as great as it might have been for various reasons the first and foremost being the apathy of the general public.Now I take it the Acts have been passed for the protection of the public and only secondarily for the protection of the honest trader ; but unfortunately for the primary object of the Act the public analyst does not receive any support whatever from the public either in the way of samples or by expression of opinion as to the proper carrying out of the Act. The result is that the public analyst finds himself opposed by all those who practise adulteration-not by any means a small class. Further he finds himself opposed by certain associations old and new who 1 think ought to look upon the analyst as their greatest benefactor; but they do not think' so and they consequently rush in with counsel witnesses and what not to stop the particular prosecution; and the public analyst not having any support from the public very often fails.And perhaps I may here state what is his position-a position very often misunderstood. The sole function of the public analyst is to analyse any food drug etc. which may be brought to him by the inspector or by any one of the general public who complies with the provisions of the Act. The analyst has nothing whatever to do with buying the articles or with any subsequent prosecution. He simply gives a certificate and, if necessary he must be able to support in the witness-box the truth of the certificate. He does not know where the articles come from he has not the slightest interest in the prosecution and he is absolutely neutral.The second case where the Adulteration Act is not as effectual as it might be is on account of the ridiculously low fines .often inflicted. I cannot do better than refer to milk an article of the greatest importance and yet it is the one which is the most largely adulterated owing to the ease wjth which it can be done. It is therefore desirable that the milk delinquents should be severely punished whereas we find that frequently the fine is put a t so low a figure as 10s which can be easily recouped as it only means the sale of some twelve quarts of water in the shape of milk. The result is that much discouragement is given to the aukhorities in putting the law in action.Now, from the nature of things it is impossible to frequently analyse the milk from the same dealer; it would be scouted as persecution and the result is that he easily recovers his fine and it is actually a premium upon adulteration. To show what perhaps might be done by the pubJic if they took mor 144 TBE ANALYST. ~~ ~ ~ interest I may add that in my district inspectors used to be in the habit of going round on the week days only and in a couple of weeks the samples improved wonderfully Once however they went round on Sunday and what was the result ‘t Instead of 1 in 6 as generally the proportion was 6 in “-but the next Sunday every sample was genuine. As to the standard the Society of Public Analysts have only fixed a low limit below which milk is considered to be adulterated.This limit was very dificult to find because milk varies within wide limits but variations below the Society’s limit are confined to a very few animals, and never can exist in the milk of a whole mixed dairy. Is it right that the general public should be deprived of their proper quality of milk because a single cow sometimes gives milk below that standard 1 In regard to this point-and I hope whatever I may say about Somerset House may be understood to be said with the highest respect because what they have done they have done with great success although they have msde a mistake in the matter of milk. It would be an injustice t o Londoners if they were prevented getting their milk of a standard up to nine per cent. because certain cows give considerably under that; quality.By enforcing this limit some milk would doubtless be withdrawn from the market but the public would only gain thereby. Well the word adulteration is very frequently made use of but the word is not mentioned at all in the Act which simply says, “The article shall be of the nature quality and substance demanded.’’ It would be well if the Act did not sometimes require an impossibility of the analyst. Unfortunately the schedule gives a form of certificate to be given by the analyst and it must be literally and exactly filled in or the prosecution may fail. We are therefore absolutely bound to follow that certificate and to say that such and such an ingredient is present in such and such a proportion and I assert without fear of contradiction, that while it is very easy to certify that the article is not of the nature required it is yet impossible frequently to say what is the nature and the quantity of the ingredient added.I think therefore that the public analyst ought to have the option of saying that the article submitted to him is not of the nature and quality required but that he is not able to state what is the absolute quantity of the added material. I may speak of wine for example ; it is comparatively not a difficult matter to say whether the colour is genuine or not but i t is impossible to say what is the nature of the colouring agent added and therefore in such a case the only result is that we are obliged to pass the article because, if the analyst varies the form of the certificate then the prosecution fails.1 am aware that this is a great stimulant to research and the analyst seeks to ascertain a means of arriving at the quantity but so long as this is not possible I do not think the law ought to ask us to do impossibilities. Now as t o some of the points raised by Dr. Bell he thinks public analysts have raised their standard of milk too high for the non-fatty solids and too low for the creams ; but why have we done so 1 because we are not sufficiently supported by the public. If an unfortunate public analyst gives a certificate that 2.5 parts of fatty residue shows skimmed milk down comes some association to argue that it is quite right and natural because when milk stands for some time in the tub and is served out a basinful a t a time the cream gets taken off so that later on of course the proportion gets low.This may be the case but it need not be so with a little care. I have made very many experiments and I find that if you have good milk to start with you may go. on serving several gallons without reducing the cream below the standard. With regard to the question as to the addition of preservatives at first sight, if the matter be of a harmless nature it would seem right to allow it to be used but on further con-sideration grave donbts arise as to this. Milk is an article which has to be treated with very great care and unless the milk-dealer is cleanly in all his apparatus and dwelling the milk is apt to turn sour. Now if he is allowed to add anything to keep his milk from turning the public lose this safe-guard and the milk may be kept in dirty rooms and in dirty utensils without readily showing the absence of sufficient care and cleanliness.I look upon this ready turning of milk as a very fortunate circumstance and as one of the great safeguards which the public haFe against carelessness in its manipulation. In the second place a milk-dealer at present cannot skim 0% much cream without the fear of making the milk turn and I have noticed that whenever I have a milk which is low in cream, there is generally boracic acid present and this is added to prevent its turning sour while he is removing the cream. Now as to spirits it is very often stated that fresh raw spirit is injurious t o health because it contains fuse1 oil but there is absolutely no evidence to prove this.Dr. Parkes sent me some speci-mens of spirits from China and the Cape which were said to have played havoc with the sailors who indulged in it freely when on shore but it turned out that the one which did such havoc contained much less fusel oil than ordinary whisky ! Some years ago there was considerable discussion about this in Sweden. The Swedes were given to brandy drinking and it was often said that the disastrous results which so frequently followed were due to drinking the fresh spirit A commission was appointed and they discovered that it was not due to the fusel oil but that this raw spirit was much liked and consequently that more of it was drank and thus it was the quantity that caused the evils and not the quality. I hope this conference will arouse the attention of the general public on the question of pure food because I am firmly conviliced that it is onIy by the co-operation of the public we can ever hope to suppress adulteration.Mr. WIBNER I must confess that my own opinion is that Dr. Bell has taken too favourable a view of the action of the Act up to the present although I agree that it has done much good I do not look upon the amount done as nearly sufficient for the machinery brought into play. I take it for something very much like a disgrace that a€ter we have had an Act a t work for eight or nine years yet the average of adulteration should still be 17 or 19 per cent. according to the class of goods selected for analysis. Dr. Bell quoted statistics taken from Mr. Herbert’s book but they are not as full as would be desirable and not by any means accurate in all respects.I have here some others which wil THE ANALYST. I45 illustrate what I mean. Taking the six or seven years 1875 to 1881 the reduction in the percentage of adulteration in seven years is only from 18-1 to 16.6 a very unsatisfactory result indeed for seven years’ work. Taking again the case of milk the adulteration of milk has increased since 1879 by nearly three per cent. and grocery shows only a reduction of two per cent.; therefore I think it is clear that an alteration is wanted and I am of opinion that schedules of limits should be enacted of such a charmter that very inferioi- articles should be excluded even at the ri9k of some inconvenience. I think there is just as much reason for excluding from retail sale a milk which has only eight per cent.of fatty solids if it be the result of a badly fed or diseased cow as if this poorness in quality were the result of adulteration ; and if the cow be incapable of producing milk of better quality then the best thing would be to send the cow to the knacker. We may in this country learn something by observing what has been done in other countries. Our 1876 Bill was the result of a compromise because when it was introduced it contained this remarkable clause ‘‘ that if the article sold was sold in accordance with the custom of the trade or locality then the vendor was exempt,” and it was to suit the spirit of this clause that nothing like standards were introduced although the clause itself was subsequently removed.With reference to Dr. Voelcker’s statements as to cattle food I may reply that the agricultural party in the House interfered with the introduction into the Bill of a clause relating to cattle foods. In America more than 3 of the United States axe under adulteration acts. They are nearly uniform in the different States and with two exceptions all of these have limits and with one or two more exceptions these are the limits of the Society of Public Analysts. It is therefore illegal in America to sell milk containing less than 9 per cent of non-fatty and 2 5 of fatty residue, and I think this ought to be used as a standard because I have heard no complaint from the United States that this standard is too high. Now again take the case of Prance. The Paris Act is a municipal one.It is much more stringent than ours and much more thoroughly enforced but the same standard has been adopted and although it has been in operation five years I have not heard of any case of a successful appeal. The matter of milk is looked upon more seriously than here as you will see when I tell you that in that city which is less than half the size of London 24 inspectors are employed to take samples and they go in couples to the shops and examine whatever they please and then take what they think proper to the Laboratory and in this way some 900 samples per month are analysed. The result of that on milk in Paris is shown by the fact that the average adulteration is only from two to three percent. while the average here is 17 per cent. of watering and 17 per cent.of skimming that is to say that in these two ways ;3. the value of the milk is taken away. I think that furnishes the strongest reason for suggesting the use of a limit an6l that the limit should be much higher than the limit adopted by Dr. Bell. Then as to two or three other points in connection with the Act; there is one point which has certainly been a success viz. the section which provides for the examination of tea the adulteration of which has been entirely sufiressed and the effect of the change in 1879 on the limit in spirits has had the same &ect. Now passing from that to the imperfect mode in which the Act is enforced in the country. The Local Government Board have the power to appoint analysts if the local authority refuses to do so but as they have no power to pay him any salary these appointments are in reality never made.This applies also to the number of samples which should be purchased. It has been put forward that one sample should be analysed for every thousand inhabitants-a very moderate estimate truly but it is seven times more than is purchased actually. Next as to the certificate of analysts This is certainly a most cumbrous document and unfortunately it is not made incumbent upon the chemists at Somerset House to use it for their reference certificates; and I think that differences may often have arisen in this way. The public analyst is obliged to say that nothing has occurred to interfere with the analysis yet milk seAt to Somerset House is frequently decomposed and that fact ought to appear on the certificate because it bears gn the second point that the certificates of Somerset House ought frequently to say not that the analysis can or cannot be confirmed but that there is nothing to show that it is right or wrong.Many cases must occur with Dr. Bell where he cannot say the analyst was not right but he is utterly unable to say that he was wrong and I think the weight of opinion should go to the analyst who made the analysis while the milk was fresh What would be the effect of raising the standard of milk as to limiting the quantity 1 I think it would be very small ; it is true that milk used in the country districts for butter and cheese would be withdrawn from those uses but these might just as well be imported so long as we can get the milk pure and if the milk area were slightly increased in extentit would make up the required supply.I was sorry to hear the remarks of Dr Voelcker in reference to the necessity for more care on the part of public analysts especially bearing in mind that in the two cases he cites in only one of the two was a public analyst involved ; and yet in both cases it would have been an analyst’s duty to condemn the cream. In the first case it is true it only contained traces of starch and they were probablyderived from the unwashed piece of calico used to strain it but if the dairyman bad allowed the piece of new calico to be used he thoroughly deserved to be caught ; and certainly I should say the same thing as to the case where the aniline had been introduced. I think sir there are so many other gentlemen who wish to speak that I shall leave the analytical part untouched.I shall simply say my opinion is in favour of passing a resolution to strengthen the hands of those who desire to introduce changes into the law as it at present stands. Dr. ATTFIELD I shall only allude to one point and that is as to the proportion of articles of food and drink which are said to be adulterated. The public draw rough conclusions from what is said in a Conference like this and from what is published from year to year respecting the results of the working of this Act and I think the one rough conclusion which they will draw is that of all the articles of food and drink which they consume 15 or 16 or 17 per cent. are adulterated. Now 146 THE ANALYST, should not like it to go forth to the public that that is the truth for what is the truth is this that of the articles which have been examined by the officers under the Act 15 per cent.are simply salid to be adulterated Why sir if we take as a matter of common sense the number of dEerent articles which are placed on our table I suppose we shall come to the conclusion that something like 30 or 40 different articles are brought before us in the course of it day and that in the course of 365 days means thousands of distinct purchases are made for a household. Now is it to be supposed that of these thousand articles 17 per cent are adulterated 1 Sir as a chemist of 25 years’ experience I protest against it. I have examined vast numbers of articles of food and drink and a still larger proportion of drugs and I say this that of all the articles which are placed upon our tables in the year and of the drugs which we are unfortunately obliged to introduce into our bodies that not one in a thousand is adulterated.It has been my lot to be asked during the past 10 or 12 years to be the chemical adviser of a body of traders who have been liable to be charged with adulteration and although it was not greatly to my interest I consented to advise them whenever they might be threatened with a prosecution ; and in some 25 cases in which this occurred I have had to advise that in about 20 or + of the cases that they defend the action and in the course of defending the action of these 20 cases where the matter had to be tried before the various impartial tribunals out of the 20 cases of prosecution how many have been dismissed? 19.In several of thoee cases it has not been a matter in which the legal officers on one side have been put in the box against men like myself on the other side but in which a few questions put by the counsel for the defendant to the witnesses for the prosecution have been sufficient to upset the case. Now I make no charges of any kind ; at the same time no man is perfect and if in the 25 cases brought before me I could advise that in -2 of the cases the prosecution be opposed and that practically in the whole of those cases the defendant was found not to be wrong then I say that if one chooses to think if one chooses to make an inference, Ghat in 19 cases of alleged adulteration the charge broke down I say you ought to take off at least 12 from the percentages alleged to exist and I therefore do not believe in drawing deductions from any such figures.Mr. HEHNEB After the ridiculous remarks to which we have just listened 1 cannot allow the point involved to remain over but will proceed at once to refute them. Upwards of 18,000 analyses have been made by public analysts every year one-fifth or one-sixth of which are declared by them to be adulterated If what Dr. Attfield says be true then the obligation on the backs of public analysts is somewhat heavy This Act has been in operation some ten years and on the 200,000 samples examined since it came into force about one-fifth have been found t o be adulterated-wholeeale injuatice must have been inflicted upon the trading public and that by the public analysts.Now it is notorious that anything can be proved by statistics but analysts were not appointed to produce statistics. I think the aim of those who supply samples is to do the greatest amount of good with the limited amount of money they have at their disposal and the aim of the inspectors is to catch the greatest number of fraudulent tradesmen and therefore inspectors who might certainly be stricter, do not proceed to buy samples of what they think may be good ; they do not try to get the average quality but to get a large number of bad samples by means of the small means they can dispose of, and so we only really get at the class of people who adulterate. Dr. Attfield is very fortunate in only getting 1 in 1,000 of adulterated articles on his table and if it be admitted that there be adulteration at all then it may be inferred that if Dr.Attfield has been fortunate enough to escape these adultera-tions somebody else has had them. This is particularly the case with poor people who buy their commodities by the pennyworth or the halfpennyworth; it is they who get the adulterated specimens, and dot Dr. Attfield who probably buys in large quantities at the Stores the extremely numerous articles with which bis table appears to be covered. It would be as easy to get genuine samples as to get adulterated but it is no part of our object to do this. Now I think although it has been shown in the statistics put forward by Dr. Bell that the percentage of adulterated articles is the same as some years ago yet every public analyst has noticed a decrease not in the actual percentage of adulterated articles but in the amount of adulterating material added.- Formerly milk used to be adulterated to the extent of twenty thirty or even sixty per cent.; now it is nearer ten per cent. and, in this respect the statistics will not show the good effect of the working of the Act. Improvement has been effected in other directions bearing more on the nature than on the quantity of the material employed for adulterating purposes. Formerly it was a common thing to find cayenne pepper adulterated with red lead and many other examples might be given At the present time poisoning is no longer to be feared ; only cheating remains. In reference to the compulsory appointment of analysts 1 may observe that although they must be appointed by the Local Government Board when the local authorities have declined to appoint them the Board has no power to compel them to get samples analysed ; what is the consequence ? In one town that I am acquainted with where the Adulteration Act is not in force but where in the country it is strictly enforced avery curious and characteristic effect is to be observed.Anywhere out-side the limits of the town the average of the samples is high; but then what do we see ? As soon as a milk-dealer for example gets inside the town he goes to the nearest pump and waters his milk. A certain proportion of samples ought to be insisted upon-so much for each thousand of the population. It should not be left entirely to the governing body of the town or district which composed as it is in a large number of cases of influential tradesmen whose interest it is not to have any analysis per-formed at all and to take every opportunity for stifling inquiry.Dr. Bell has been exceedingly complimentary to public analysts in acknowledging that a considerable amount of strife has taken place between them when their cases have been referred to him Of the many thonsand samples which have been analysed a very small number have been referred to Somerset House-every year onl THE ANALYST. 147 some twenty-five or thirty cases a very small proportion on the total number of analyses. Even on this very small number in only about one-half have the analysts been contradicted. Minute as this proportion is it is in reality much smaller because it is frequently not a question of fact a t all it is simply a matter of opinion.In the cases alluded to they were nearly all cases of milk adulteration-it is a question of difference in quantity and not as to the fact of its being present. With so many thousand analyses some mistakes are sure to be made but the exceedingly small number of these mis-takes reflects I think great credit on the general body of analysts. Ihe great grievance is that we have to refer our analyses to a Court of Appeal a t Somerset House which is in reality far less expe-rienced than we are. They bave perhaps some six hundred cases in. the course of the year where we have as many thousands. Dr. DE CHAUMONT There can be but one opinion as regards the success of this conference and I think that we may felicitate ourselves tbat so much has been attained.I only wish for the consumer’s sake that I could take the roseate view that Dr. Attfield does but I must say that I cannot by any means declare tbat only one in a thousand articles submitted to my examination was adulterated. In the matter of milk alone not only on account of its importance as a food but of the extreme ease with which it is tampered with the proportion is-larger very much larger than has been suggested. With regard to the question of how we are to deal with the cases of analysis, I quite agree with the suggestion that a good deal of loose statement is made as to the presence of adulteration in articles of commerce. It has been stated to me that a good deal of beer sold in my neigh-bourhood was adulterated with tobacco ; I examined several samples but the result was that none was found.Then as regards spirits it was supposed that the spirits sold a t one of the establishments in the neighbourhood were adulterated with tobacco. Well some samples were sent me but I found no tobacco except in one case and that I attributed to the fact that the man who brought me the specimen had put his pipe in the same pocket as the bottle containing the sample. There was one point which is very important and that is whether we ought to deal with articles as avowedly articles of commerce-prepared articles that is to say-or whetber we should deal with them as articles which ought to be supplied in a pure state As regards beer as such a variety of material is used no special standard can be laid down but I venture to say that this is only one aspect and does not apply to such articles as milk butter or cheese.But with regard to milk I think we are entitled to demand to have it as it comes from the cow as I have mentionedin this room before,at a Milk Conferencewhich tookplace here when there was a very interesting discussion on the subject. One gentleman suggested that we should take milk as an article of commerce and as having different standards of value that if he had very rich milk it was hard that he should have to sell it at ordinary prices whereas if he took the cream away it would still keep to the standard of poor milk but this would be very bad for the public.The milk tends to undergo change and we have no security for the means adopted to bring it down to the standard of poor milk. The water added may be pure water but we have no guarantee that it may not be drawn from a filthy well in the vicinity of the farm-yard ; therefore there can be no excuse whatever for this suggestion. With regard to the question of butter and cheese I think we may apply similar rules. Butter is manufactured to a certain extent but the chief point in which it differs from the natural product is in the addition of colouring matter but this is in deference to the taste of the public who prefer it and the same in regard to cheese. Now I tbink the Adulteration Act may be amended in this way that no mixtures of any pure articles ought to be tolerated ; that coffee if sold as coffee ought to be sold alone and no mixture with chicory should be allowed ; and the same principle may be applied to many other things.With regard to the difficulties which the Adulteration Act has met with they are many. One of the difficulties is the different modes of analysis and the uncertainty of the best mode the necessary pxperience of analysts and too much dogmatism. But I think we may safely say that these have fbr the greater part been got over; but there is certainly one difEculty which remains and will I fear remain for a long time and that is that this Act like many others is beyond, is above the standard of morality of the present time. I say this advisedly for where any tradesman would certainly scruple to take money out of your pocket by pocket-picking yet he sees no objection to doing this in an indirect way by adulterating the articles he deals in sogs to obtain a larger profit, yet it is indisputable that one is just as immoral as the other only pubIie opinion does not back us up in this case and this view prevails very much with magistrates in this country.Then if you insist upon applying the penal clauses of the Act and fine the recalcitrant tradesman repeatedly people say it is persecution but supposing that a man belonging to the criminal classes picks your pockets and is taken up before a magistiate and is punished and on coming out proceeds to pick your pocket a second time do you think the policeman will not take him up because he had just been taken up? Until we reach this point of making it felt generally that adulteration is a distinct wrong against society there will not be very much chance of getting it carried out to its fullest extent ; there is no doubt that in France it is camied out in a much more despotic manner but I think the machinery of the Act should be extended so much that it will no longer be worth while to adulterate at all and that when the man is convicted of adulteration then that he should be disgraced as if he had been tsken up for picking pockets.As a large number of names were still inscribed to speak and as time was short the Chairman put it to the meeting whether it would not be desirable to adjourn the further discussion of this important subject till the next day at the same hour and this resolution was carried with but one dissentient voice 148 THE ANALYST.15~13 JULY ADJOURNED DISCUSSION. The CHAIRMAN commenced the proceedings by calling on Dr. Muter to address the Conference. Dr. NUTER In continuing the discussion upon the subjects so carefully brought before us in Dr. Bell’s very thoughtful paper yesterday and afterwards so ably sketched out and divided into heads by our respected President I ;hope I shall not permit myself to descend into those personalities and contentious matter which has been brought into the matter yesterday by people who wish to run down the public analysts. 1 donot wikh to go through the whole of the heads that our chairman has mentioned, but I propose to inquire in support of Dr. Bell’s paper (l) Did adulteration really exist to a marked extent before the passing of the Act of 1872 and has that adulteration been checked to any extent by the passing of the Acts ? (2) I wish to inquire whether the Act as it at present stands ought to be amended, and in what direction and whether and how far we ought to follow the doctrine of limits or standards ? Now in the first place did adulteration really exist before 1872 and was that adulteration if it so existed deleterious adulteration or was it only of the nature of what has been called ‘( commercial immorality ” ? Now in his paper Dr.Bell has ably collected from the reports of the Lancet commission, and other sources instances in support of the contention that adulteration did exist. I have perhaps, got some small title to speak on this point seeing that I am one of the two or three remaining living analysts who really trained themselves to food analysis before the passing of the 1872 Act having been engaged on a commission like that of the Lancet-I mean the commission of the Fuod Journal.Now I was looking back last night to those old results in 1S70 and 1871 and I find that out of twenty-throe samples of coloured sweets purchased all over London by the editor of the Jbod journal thirteen were adulterated by a regular painted coating of chromate of lead and three of them also contained streaks of vermilion as well thus proving the deleterious adulterations which really then existed. As regards the ordinary ‘( commcrcinl immorality,” out of forty-seven samples of coffee sold as pure in that year, thirty-one samples were more or less mixed with chicory and in seventeen cases the chicory itself was mixed with something else.Now my object in bringing up this old story is that it is not merely hearsay but I stand here as a living witness that such things did exist some years ago; and I also mean to assert that the passing of the Act has produced a wonderful amount of change and benefit to the public. During the first year or two after the Acts were passed we still could get hold of those painted sweets ; but for the last few years of the many hundred sweets brought to me by the inspectors not one of them has contained any deleterious colouring matter and I say therefore that the Act as it stands has shmped out all aaulterations of this description. What actually takes place now is only R form of commercial immorality,” namely selling one article for another.One other thing I may say on this point. In looking over the books of the South London Public Laboratory where the work is done for something like seven districts and boroughs I find that since 1872 y e have examined over ten thousand samples of food and out of these ten thousand we have had occasion to have our certificate brought into court upwards of a thousand times and I am happy to say that in every case except one, that certificate has been supported. Now that is in my opinion a practical answer to the experience of one of the speakers yesterday who after announcing himself in a very loud voice as the analyst to a Defence Association tried to bring forward a statement to the effect that it was all very well for Dr.Bell to quote the public reports of the Local Government Board but let them be brought into court, and they would be put out before an independent tribunal. In proof of this he instanced twenty cases where he had conducted the defence and where in nineteen out of twenty cases the analysis had been quashed. Fortunately exceptions only prove the rule ; and at this moment it will not suit the present stage of my remarks to say why these nineteen prosecutiogs failed. Let tis say for a moment that they failed through the fault of the analyst ; but against that let us compare the number analysed all over England-nay compare even the limited experiences of South London only where over a thousand prosecutions have taken place and in only one case so far as I can recollect has there been a chemical failure-I mean a distinct conflict of chemical evidence-and then what is the logical answer 1 It is not long ago since 1 happened to be speaking to a very eminent foreign scientific gentleman who expressed to me his astonishment at our having a body of chemists like that of the public analysts who go on year after year in the fierce light of public criticism and make 80 few mistakes.Nobody is infallible; we must all make mistakes; but I say that the errors that-have been made by public analysts are extraordinarily few considering the enormous amount of samples which have passed through their hands. Now as regards the effect of the Act at the present time just let me recall another cir-cumstance. I find that in the first year that the Acts came into operation in the districts of Lambeth and Wandsworth we prosecuted for adulteration cqual to twenty-five per cent.and in Lambeth i t was even worse ; in Wandsworth this last year it has come down to six and a half per cent. and in Lambeth to twelve per cent. I think you will agree with me that there is direct proof of the benefit of the Act ; xou cannot say anything against these statistics because the action of the local authorities has been alike throughout. In Wandsworth especially where the Act is carried out in a most excellent manner by the local authorities there is an inspector whose sole duty is the collecting of specimens and notwith-standing this he can only get six per cent. of adulterations and I say this is a real proof of the benefit derived from the working of the Act.Now let me pass to the second point-that is ought we to be satisfied with the Act as it now stands? In my opinion we ought not to be quite satisfied because there is no reason why what is done with excellent results in one parish should not be done in another. Now I purposely limit my remarks to my own personal statistics ; I take my own particular districts ; and I find in one district mhere the inspection is very complete where the amount of samples amoun THE ANALYST. 149 to never less than four hundred annually the percentage of adulteration sinks to six. In the next district where the number of samples only amounts to three hundred annually there we only succeeded in reducing the adulteration from twenty-five to twelve per cent.Then I can follow it in other districts, where I get perha,ps only twenty or thirty samples in the whole year and the most of them are invariably bad; and then lastly I come to the famous district of Newington where I as public analyst have never received a sample in my life; but I really think if some of the newspaper editors were to have some samples purchased in those districts there would be some rather astonishing revelations. Admitting then that the Act requires some amendment what are the points in which it requires alteration? The first thing that strikes me is that we ought to have a compulsory appoint-ment of inspectors. The Local Government Board can make it compulsory to appoint an analyst but local authorities are not obliged to appoint an inspector and therefore the analyst gets nothing to analyse.Now I say the inspector ought to be nominated compulsorily and I say it ought also to be made compulsory that the number of samples purchased in the course of the year should bear some reasonable ratio to the number of dealers in food within that district. Perhaps it might be too much to expect but really every dealer ought to be visited at least once within the year. Particular dealers ought not to be singled out and ‘‘ sat upon ” by the insuectors but a regular system should be instituted and a sample taken from every dealer. 1 therefore think an important point would be the compulsory purchase by a compulsory inspector of a certain compulsory number of samples annually. Now the next point and here I may differ from Dr.Bell ; if I listened to his paper aright he expressed the opinion that it was perhaps not desirable to have too many limits or standards. Now I am going I fear to the other extreme for I amprepared to say that the true reform which is wanted in this respect is that our Act should be assimilated in many respects to the New Zealand Sale of lFood and Drugs Act. I consider that the fixing o€ limits (remember I do not mean standards but limits belov which the dealers shall not go)-I think that the iixing of reasonable limits-not too high but reasonable fair honest limits is a point upon which we all agree. We had the case vgry prominently brought before us in the discussion on milk by Dr. Bell and he pointed out what a very variable thing it was and then unless I misunderstood him he said that he considered tha% the fixing of a limit for milk would tend to restrict the trade output; and be commercially disastrous.I do not believe this because it seems to me that if you have a variable article like milk you ought to take the lowest possible honest milk and there’s your limit and below that your milkman must not go but he can go above it as much as he pleases. Ile can say to the public I supply a better milk than So-and-so who waters down to the limit and the man who sells the best milk will in the long run I cannot doubt do the best business. Why reasonably low limits should affect the trade at all 1 cannot see ; perhaps other speakers may show this but I confess I am unable at the moment to understand it.Now this is the proposition I am about to make as regards the amendment o€ the Acts. I hold that there ought to be st permanent Commission appointed by law ; that this Commission should consist of an eminent chemist appointed by the Government (Dr. Bell), another eminent chemist appointed by the body of public analysts and thirdly it should contain a man t o represent the Chamber of Trade so that the Trade would have a practical voice in this Cornmission. I do not limit the Cornmission to three but there should be a commission on this basis. Now it should be the duty of that Commission to examine in turn all the ordinary articles of food and drink and to lay down LL limit of quality below which the articles shall not sink and then when that Commission makes its report (which it would do at certain stated times) an order of the Queen in Council should be sufficient to give effect to such limits.Here we have an end of all heart-burnings the traders themselves would have a voice in the Council and everybody would know what was the limit of 66commercial immorality.” I am not proposing a chimerical idea but I suggest a scheme which hccs been already adopted in New Zealand during the last year to the extent of commencing a schedule of standards and ordering this schedule to be added to from time to time by the Governor in Council on the recommendation of a Commission of Experts. My commission is not to be composed only of experts but is to contain a representative of the traders as well and once fair and honest limits were laid down I believe the Act would work much more smoothly.Now just one word before I leave the question of limits on the subject of milk. There has been a great talk about milk and I have rather radical views as to milk. I think the great; mistake that has been made by everybody both by analysts and others is that they have been too anxious to draw hard-and-fast limits hard upon one particular quality of milk. Now it seems to me you ought to have a sliding-scale limit as I call it. It has always been my experience (and that experience has not been small for I was just calculating out before I came here that it extends to over 6,000 analyaes of milk) that when the non-fatty solids in unwatered milk became low there was invariably an increase of fat in the milk and I have always from the fist made a practice of never condemning a milk even when the non-fatty solids fall to 8.5 if that milk contained an excess of cream because I look upon it as a fact that what you lose in one you gain in another.I say that our standards should be so fixed that provided the cream is over a certain limit that it does not matter if the non-fatty solids are rather low ; on the other hand let the cream get under a certain proportion then the milk has been skimmed and the non-fatty solids require to be present in a larger proportion. I would judge the milk upon a certain standard ; if the fat exceeds a certain amount and if the fat is less than a certain amount then judge it upon a more strict standard and in tbat way the public always get full value for their money.These views are perhaps a little radical but I hope still that before many years are over our heads we will have a commission appointed which will have the power to make limits and will adopt milk limits of that sliding-scale nature which I am now advocating. That is all I had meant to say to-day as regards the principal topic but since I came into the room 150 THE ANALYST. have been asked by some of my colleagues to refer a little to some remarks that were made yesterday in I venture to say rather questionable taste and to answer them. In the first place Dr. Voelcker (a man who as a general chemist we must all esteem) made in my opinion rather a step in the direction of bad taste in giving what he called a little advice to public analysts. This advice was, that public analysts should not be too hasty.Very good advice and I- do not object to anybody advising me 1 I am very pleased to have advice but the question arises do I deserve to have advice given me ? Have I done that which entitles me to a sermon 1 Now when a man gives advice he pre-sumes he has a right to put himself in that superior position whence he can give such counsel and that he has a sufficient reason for giving it. Now Dr. Voelcker no doubt feeling this did show a fancied ground for giving advice but let us here recall what it was. In the first place there was a very serious case in which some cream had been sent to him ,which he ascertained to contain starcb but I am not going to jump to 9 conclusion like a public analyst,” said he to himself and he sent to tlic place the cream came from and asked What did you filter your cream with B Cloth sir was the reply.Was it new 1 Yes sir. Oh all right then the starch came off the new cloth used for straining and so its presence is an accidental circumstance ; therefore muraZ ‘‘ Do not jump to a conclusion.” Here however is a difficulty; a man must be in a particular position before he can do these things. If our friend who has given us the advice had been in the position of a public analyst who does not know where the specimen comes from and who is bound to say by law what it does or does not contain he would have had to state that he had found some starch and to leave the other party to explain the matter. The same remark applies to the other cream where aniline was present A public analyst would have been obliged to certify to its presence and I am bound to say I think a conviction would have been justified on the ground of carelessness.Another amusing thing is the matter of the 20 prosecutions which failed alluded to by the loud-voiced speaker of yesterday I have already mentioned. You all doubtless imagined from his indignation that they were very serious failures and that the adulterations did not exist at all but unfortunately-that is unfortunately for his argument-the failures were not attributable to this. Here is a case in point ; there was a public analyst who had some scammony sent him to examine-now scammony as you are probably aware is rather an expensive drug and therefore more likely to be adulterated-well in this scammony he finds chalk unmistakable evidence of the presence of chalk and in a large proportion.The public analyst on referring to the official pharmacopeal description finds that scammony should not effervesce on the addition of hydrochloric acid and it does so effervesce. What is the analyst to do? it is not a question for him as to how the chalk came there; all he is concerned to know is that it is present and he reports accordingly. The case comes into court and the defence-our friend who addressed you yesterday-stands up to explain the presence of this chalk which he considers the most natural and innocent thing in the world Re says in effect, that you must not mind the chalk being there at all it is not an adulteration. Scammony root grows in a chalky soil and therefore not unnaturally gets mixed with chalk in spite of all the care imaginable and moreover as the resin is exuded into little shells from the incisions made into the root by the poor innocent Turks what is more natural than that they should put some chalk into the shell to stop it sticking.What has that to do with the analyst ? The explanation was plausible and succeeded but then the analyst had only to say whether the chalk was there or whether the drug was pure and he had not to occupy himself with all this funny story about the Turks and the chalk, Nearly all these failures in prosecutions which this gentleman spoke of yesterday have been of that nature. Here is another example of much the same sort. There was an analyst who had brought; to him an article which was called milk of sulphur and he found it to contain much sulphate of calcium and the authorities took the matter into court. It was explained by our friend that milk of sulphur formerly naturally contained this ingredient and that the public always preferred it in this form. Well that was all right I suppose and accordingly the case was put out of court. This, however was nothing against the analyst. It was simply a question for him as to whether natural scammony root or sulrhur contained carbonate or sulphate of calcium but whether their presence was admissible was a question of lam and the proper way of settling such questions is by legal proceedings. Why then say the analyst jumps to a conclusion because the prosecution does not succeed on a point totally uhconnected with chemistry and which could only be settled by a court of law 1 I think I have said enough to show you that the attacks which have been made from time to time upon public analysts are in many cases unjust. We do our best to tell the true ohemicaZ facts, as truly and exactly as we can and with what ZegaZ results follow we have nothing to do. It has been said Why do not analysts warn the authorities not to prosecute in debatable cases 1 but I can only say that in practice I have twice done so in matters of drugs and been plainly but firmly told to mind my own business I (To be continued in o w nem!.