ADULTERATION OF FOOD

To label the adulterator of food as a criminal would, in the majority of cases, be too harsh a sentence, but in the worst forms of adulteration—those in which food that is positively bad is made to appear good—he more than deserves the title. Although in the larger proportion of instances the actual pecuniary loss inflicted upon the consumer by the sale of adulterated food may be but trifling, the loss suffered by the community collectively through various forms of petty frauds of this nature reaches an enormous total in a year.

Some idea of the extent to which the public is thus defrauded may be gathered from the instructive figures published some years ago by Professor Long in the Nineteenth Century.

In his article it was estimated that 1,400,000,000 gallons of milk were produced annually in the United Kingdom, of which over a third was sold in the form of milk, the remainder being converted into butter and cheese. Assuming that a tenth part of the milk were adulterated by the middleman, the loss to the farmer would represent over £600,000 per annum. There is little doubt but that this calculation underestimates the amount of milk adulterated by the addition of water or by the separation of the cream.

The evidence given before a Select Committee of the House of Commons appointed to deal with the Food and Drugs Acts suggests that probably one-fifth of the butter imported into this country is adulterated, while it is almost impossible to form any estimate of the loss to the consumer from adulterated groceries and from the sale of foreign meat as “best English.”

With few exceptions, nearly everything we eat or drink—in fact, nearly everything we buy—is liable to be substituted for what we want, or to be mixed with something else that we do not want—at all events, at the price we have to pay for it.

There is thus considerable excuse for the amusing blunder made by a counsel who was cross-examining Mr. Siemens, the electrical expert, in a case in which there was a dispute about the working of some electrical plant.

“I think, Mr. Siemens, that you have had a long experience in connection with electricity?”

“That is so.”

“Well, now, I want you to tell me whether in the course of all your experience you have ever known electricity to be adulterated?”

“In only one instance,” replied the witness.

“And when was that?”

“In the phrase ‘greased lightning,’” was the instant witty reply of the electrical expert.

But there are few commodities which can be bought or sold that have the clean record of electricity. In every direction, competition is daily becoming keener, and rival firms “cut” the prices, each forcing the other to sell either with the minimum of profit or to stop selling altogether.

Under these conditions there is a strong temptation for a small firm in danger of being crushed out of existence by its competitors to avail itself of the additional profit afforded by adulteration, and thus be able to sell its goods at a lower price than its more scrupulous rivals.

In many cases the adulterated articles are sold unknowingly, the shopman being tempted by the offer of an alleged genuine product at a very low price, while the foreign manufacturer who supplies him with the goods cheerfully accepts the risk of prosecution, well knowing that he cannot be brought to book.

Frequently the adulteration is most skilfully effected, and every fresh advance in the chemical methods of detecting foreign ingredients is scientifically met by the adulterator. The old gross forms of adulteration are, for the most part, things of the past, save, of course, in the case of foods like milk, which contain much water, and where the temptation to increase the amount is frequently too strong to be resisted.

The old story of the grocer who called his apprentice to prayers after telling him to “water the treacle and sand the sugar,” has lost its point, at all events as regards sanding the sugar. The fraud is too palpable. And the same may be said of other unskilful forms of adulteration, such as the addition of gypsum to flour, chalk to milk, starch to butter, and so on.

In short, adulteration of to-day has become a fine art, and the public analyst has strong suspicions about many a sample, which he dare not condemn, since it might possibly be genuine, though of poor quality.

Long before the days of the public analyst there was an official who was, in a sense, his forerunner, and his methods were simplicity itself. As might be guessed, our ancestors three or four hundred years ago, were mainly concerned about the strength of the national beverage—beer, and they appointed officers who were known as “beer conners,” to visit the different ale-houses, and to taste and examine the liquor that was being sold. According to Mr. Sidney Lee, John Shakespeare, the father of William, was appointed an ale-taster in 1557.

The test to be applied needed no complicated apparatus or chemical reagents—nothing beyond a pair of leather breeches, which were called the “conning breeches.”

The beer conner would put these on, and having poured a little of the ale on to a wooden bench would sit down in it and patiently await the result. If after a given time he found that he was glued to the bench, the ale contained sugar, and was condemned as adulterated, but if he could rise without an effort the beer was passed as pure.

The oath to be taken by these beer tasters or conners ran as follows:—

A public analyst of to-day might well envy the easy lot of the beer conner, who had no difficult problems to solve, and who, if he condemned ale that had sufficient “body” to hold him to his seat, was sure of the support of the government officials.

To the layman it may seem strange that a conflict of opinion should ever occur between analysts with regard to the genuineness of a sample of food, and that it should ever be possible for an accused salesman to bring rebutting scientific evidence. A consideration of the following points, however, will make this clear, and show how such different opinions may be honestly held. (1) Food products may consist of entirely dissimilar substances, which may readily be distinguished by suitable tests, as, for instance, pepper and salt; or (2) the food may contain a special constituent which is either entirely wanting or only present in a smaller proportion in other allied products. It is mainly with foods of this latter description that the difficulties of the public analyst arise.

For instance, butter fat contains a large proportion of certain volatile compounds, which are either absent or are present in much smaller quantity in the fats used to adulterate butter; and thus an estimation of these volatile compounds affords a means of judging of the purity of the butter. Thus, if only half the normal quantity of volatile compounds is present, the conclusion is drawn that the butter is adulterated with an equal quantity of foreign fat, and so on.

The task would not be difficult if butter fat were always constant in composition; but, unfortunately, there are often wide variations in the proportion of ingredients, and it frequently happens that the public analyst has to give his judgment upon a sample, which might either be a butter very rich in the characteristic volatile substances and adulterated with 10 per cent. of foreign fat; or it might be a genuine butter that was very deficient in these volatile compounds.

This, then, is the dilemma. If the analyst condemn such a sample on the strength of this and other tests, he may be confronted by the evidence of other analysts who will give their opinion that the butter is genuine; and if, then, the matter be referred to the Government analysts, their report may or may not corroborate his, and in the latter alternative the authority instituting the prosecution may have to pay heavy costs.

It is well known that butters are scientifically blended with foreign fats so as to fall just on the border line between abnormal and adulterated samples, and the analyst is frequently compelled to pass such a butter as genuine, lest he should unwittingly do an injustice.

A large proportion of Dutch butter is abnormal in this respect, and has been so frequently condemned as adulterated by English chemists, that protests have been made by the leading Dutch analysts.

The reason for the abnormal character of Dutch butter appears to be that the cows are left too long in the fields, for as soon as they are stalled for the winter, the character of the butter gradually becomes normal again.

These details have been given at some length, for they are typical of the problem which the public analyst has to solve in the case of many natural products, i.e., to decide whether a food is adulterated or only naturally of poor quality.

There is no special difficulty in the analyses; it is a question of interpretation of the results.

The chief culprit in the matter of the adulteration of butter is the small dealer, who buys margarine from the margarine manufacturer and skilfully blends it with butter in a proportion that is small in a single instance, but is sufficient to bring him in a handsome profit in the course of a year.

Owing to the difficulty of detecting such small additions of margarine to butter (which, as was explained above, is due to the variations in the natural product) a most ingenious device has been adopted in some countries.

This is the addition of a small quantity of a “latent colour” to the margarine, so that, although it appears yellow, like butter, its colour can be changed by the application of a single reagent to pink or blue, and its presence thus revealed in a mixture of butter and margarine.

Several years ago an attempt was made in some of the United States to compel manufacturers of margarine to colour it pink, so that it could not possibly be palmed off as butter, but as this law was found to have the effect of stopping the sale of margarine altogether, it is no longer enforced.

Various substances have been suggested as suitable for the latent colouring matter, such as starch, which turns blue on contact with iodine, and certain colourless coal-tar derivatives which change to pink upon the addition of an alkali or acid.

There are numerous objections to the use of some of these compounds. Thus, starch may be washed out of the margarine by a simple treatment with water, while a coal tar derivative that turns pink on contact with an alkali is too sensitive an ingredient for everyday use.

A far more satisfactory substance than any of these was found in the oil derived from sesame seed. This is a wholesome oil with a fragrant odour and pleasant taste, which is largely used as a salad oil in certain parts of Europe. It is one of the few vegetable oils that can be detected by means of a special colour reaction; for on treating the oil with a particular reagent it gives a bright rose colour, and the test is so sensitive that it will detect the presence of even a small percentage of sesame oil in other fats.

A compulsory addition of a small amount of sesame oil to all margarine, therefore, affords an absolutely certain means of recognising the margarine subsequently. The first country to adopt this plan was Germany, where a few years ago a regulation was made that all makers of margarine must use 10 per cent. of sesame oil with the other ingredients. Belgium has also adopted the same plan of earmarking the margarine produced in the country, and has thus simplified in one direction the problem of detecting petty adulteration.

A similar problem has to be solved in dealing with milk, the proportion of cream in which varies naturally to such an extent that it is possible to add a considerable amount of water to a rich milk without bringing it below the level of a poor but genuine milk. When such a sample of milk has been condemned, the analyst has often been confronted by an appeal to the cow herself.

But even the specious notice which was for years to be seen over a dairy: “Our customers may come and see the cows milked into their own jugs,” is no proof that the fluid they yield is necessarily “milk.”

For the up-to-date dairyman has discovered how to adulterate the milk at the other end of the cow. He has found that by giving her certain food in excess he can make her produce an abnormally large quantity of milk which lacks the right proportion of cream and other constituents of genuine milk. It has more than once been ruled by a bench of magistrates, and more recently in the High Court, that all is not milk that comes from the cow, and that a customer who asks for “milk” is entitled to get something with certain definite characteristics.

Even in cases where there would be no such escape from the results of the analyst’s certificate, the ingenious adulterator is by no means at the end of his tether, but has numerous dodges upon which to fall back.

One of the best known of these is the “notice dodge,” examples of which must frequently have been seen by everyone.

A notice, often in very small type, is put up to the effect that the seller will not guarantee that the goods he sells are genuine. Then when he is summoned for selling, say, adulterated milk, he produces his notice and claims that that indemnifies him.

A very amusing instance of this notice dodge being carried to its logical conclusion was witnessed in Merionethshire a few years ago, when the Chief Constable of the district reported that all the shopkeepers had put up notices stating that “All goods sold here are adulterated.”

A similar deadlock occurred, in 1903, in Buckinghamshire, and there the County Council forbade such notices being exhibited, though it is doubtful whether it was within its legal rights in so doing.

The plausible excuses put forward by the perverted ingenuity of the adulterator to escape conviction are innumerable. Mistake on the part of the seller, warranty with goods obtained from abroad, and the shop-boy as scapegoat are among the most common forms of defence.

The extent to which a legal quibble may be carried reached its limit perhaps in a prosecution that occurred a few years ago. In a certain village there was only one shop, and that was a co-operative store, of which the whole of the villagers were members. A county inspector bought “pure” coffee at this shop, and on analysis the coffee was found to contain 90 per cent. of chicory, and eventually the manager of the store was fined.

For the defence, it was urged that the villagers were themselves both shopkeepers and purchasers, and, therefore, could not be prejudiced by the sale of adulterated goods. The inspector, however, was not a member of the co-operative store, and on this ground the prosecution was successful.

But if one of the villagers had bought the coffee, it is doubtful whether any fine could have legally been inflicted, for it would have been a case of co-operative adulteration.

A very common method of avoiding the attention of the inspector is a refusal to supply him with the goods. In a small town the dishonest tradesman will be on his guard against suspicious looking individuals, and should he consider them to be agents of the inspector will refuse to serve them.

A fine is imposed for refusal to sell, but this usually involves the shopkeeper in considerably less expense than a fine for selling adulterated goods, while he retains his character as an upright citizen.

The question of preservatives in food is typical of the present chaotic state of the law with regard to the adulteration of food.

A Parliamentary Commission sat for a long period, and finally issued a report, the recommendations of which were allowed to remain recommendations, and every analyst and public authority must still put its own interpretation upon what is and what is not permissible.Preservatives are undoubtedly used in an absolutely haphazard way. Milk is preserved with all kinds of substances, chiefly boric acid, and at one time, formalin; butter and hams with boric acid; and jams with salicylic acid and similar compounds. Thus, at the end of the day, an unsuspecting individual may have consumed a considerable quantity of various antiseptic agents.

Everyone will agree that preservatives of every kind ought to be prohibited in milk, the more so since it is the staple food of young children and invalids, and in the case of butter the presence of a preservative should be notified, as recommended by the Commission.

A little boric acid in ham probably interferes much less with the digestion than an excess of salt, but it is right that the consumer should be given his choice of spoiling his own digestion in the way that pleases him best.

An objection brought against such notifications of preservatives in food is that they would convey no meaning to the public, but the commercial travellers of rival firms would certainly not lose the chance of making capital out of the notices of their opponents.

Nearly all the non-alcoholic wines and lime juice cordials in the market are heavily preserved. But the fact that the public demands an article that shall not ferment after the bottle has been opened, and that prosecutions for the use of preservatives are spasmodic, makes it impossible for the manufacturer to discard them. If he did so under the present conditions, he would no longer be able to compete with other firms who continued to take the risk of prosecution.

Moreover, it is no uncommon thing for the defendants in these cases to call as witnesses on their behalf gentlemen holding positions as medical officers, and cases that are well defended are almost invariably dismissed.

The manufacturer of non-alcoholic wines stands in a very difficult position. If he employs preservatives in sufficient quantity effectively to stop fermentation he is liable to be prosecuted under the Food and Drugs Act. If, on the other hand, no preservative is used, the liquid is liable to ferment, and the manufacturer may then be prosecuted for selling a fermented liquid without a licence.

Hence it follows that if the use of preservatives in lime juice cordial and the like is to be prohibited, the law ought to be rigidly enforced and not applied in the present haphazard fashion, which allows one manufacturer to sell his goods unchallenged for years, and drags his competitor into one police court after another.

It is hardly fair that matters which are so much questions of opinion should be left to be fought out in the police courts before magistrates who have no technical knowledge to deal with them.

The position, however, was well put by a magistrate a year or two ago in giving his decision in a prosecution for the sale of lime juice cordial preserved with salicylic acid. Evidence was given by chemists and medical men for the prosecution that such an addition was injurious, while a number of scientific witnesses of equal eminence were present to support the view of the defendants.

The magistrate, without calling upon the defence, dismissed the case. He held that there was an irreconcilable conflict of opinion between the purists who would allow no preservatives whatever in such products and the manufacturer who had to meet the popular demand for such an article that would keep after it had been opened, and he considered that it had not been proved that the amount of salicylic acid was in excess of that needed for that purpose. Incidentally he remarked that if notification of the addition of such preservatives on the label were made compulsory, “then the fun would begin.” You would see notices of So-and-so’s lime juice preserved with sulphide, “harmless, but with a smell of bad eggs.” Or of So-and-so’s lemon squash, “preserved with salicylic acid, refreshing, but ruinous to the digestion.”

One of the recommendations of the Departmental Committee of 1899 was that means should be provided for the establishment of a separate Court of Reference, which should deal with the question of preservatives in food and decide which should be permissible and in what quantities they should be allowed.

Such a Court of Reference, in which there should be representatives not only of the medical and chemical professions, but also of the large manufacturers and dealers in food, would tend to remove the present state of uncertainty on this point.

Looking at the matter from a practical point of view, it seems to be an impossibility to eliminate the use of preservatives from all articles of food, and it would be a far more satisfactory course if a via media could be found between prohibiting their use absolutely and leaving it to the manufacturer to dose his products with any quantity of any antiseptic. Evidence could be heard by such a body of official referees, who, after taking into consideration the views of all concerned, could from time to time issue authoritative regulations, which would be binding upon everyone.

It should also be part of the duties of such a Court to see that the regulations were rigidly enforced, so that a manufacturer who carried them out should not suffer by the competition of another manufacturer who (as at the present time) ran only a trifling risk of prosecution in ignoring them.

Another advantage of such a proposed Court of Reference would be that the manufacturer would no longer be liable to a criminal prosecution on points on which there is no agreement between the highest scientific authorities in the country.

Under the present conditions, a town or borough council, using the ratepayers’ money, may attempt to get a decision on the subject of preservatives in an ordinary police court. The manufacturer, if he is rich enough to pay for the necessary expert evidence, will probably succeed in getting the case dismissed, as, in fact, has frequently been done.

But the magistrates’ decision carries no finality, and is not binding upon anyone else, so that the borough council may raise the question again, and prosecute the same firm for the same alleged offence in the same court. If, instead of selecting the same firm of manufacturers, which would have the appearance of vindictiveness, they bring an action against another firm which cannot afford the £200 to £300 required to win an action of the kind, and the case is tried before another magistrate, they may succeed in getting their victim heavily fined, and justice would thus be reduced to the absurdity that, while one magistrate held that there was no offence, his brother magistrate decided that a criminal offence had been committed. It may, perhaps, be mentioned that this is no imaginary picture, but is based on actual occurrences.

Another question which has been the subject of almost as many conflicts as the addition of preservatives is the colouring of preserved peas with a small trace of copper.

Many of the prosecutions have been successful, but quite as many have been dismissed. The public demands a green colour in the preserved peas it purchases, and it is apparently impossible to have this without the addition of copper.

Formerly a vigorous campaign was carried on in France to prevent any addition of copper whatsoever, but it was found to be impossible to enforce its absence, and the attempts to do so there have long been abandoned.

A better course than spasmodic prosecutions, frequently abortive, would be to fix a limit to the amount that might be used, and to render it obligatory upon the manufacturer to state prominently upon the label that the peas were coloured with copper.

It may be mentioned in this connection that Professor Tunnicliffe issued a minority report to the main report of the Departmental Committee, in which he recommended that the amount of metallic copper to be allowed in preserved vegetables should not exceed half a grain per lb., and that its presence should always be declared.

The colouring of sugar by means of tin salts stands upon a very different footing, for in that case the colouring is done with the definite object of deceiving the purchaser.

At one time, pure Demerara cane sugar, which was brown from the presence of certain vegetable impurities, had a great reputation for its fine flavour, and still fetches a higher price in the market than purified beet sugar.

This reputation has been traded upon by certain unscrupulous sugar dealers, who have discovered how to treat white beet sugar with a tin salt or with aniline dye-stuffs so as to give it the appearance of the old genuine Demerara cane sugar.

At present it is practically impossible to distinguish, except by the flavour, between absolutely pure beet and cane sugars, but the dyed product is a very different substance from the brown Demerara sugar, and there have been numerous convictions for the fraudulent substitution of the one for the other.

The presence of traces of arsenic in food products is a very much more serious matter than the presence of a small amount of copper.Arsenic is undoubtedly a cumulative poison, and the effects produced by the long-continued repetition of small doses were shown by the numerous fatal cases of poisoning caused by drinking arsenical beer, in the poisoning epidemic a few years ago.

It may be safely asserted that for twenty years before that outbreak it had never occurred to anyone to test beer for arsenic. The possibility of its being present ought to have suggested itself, but apparently it never did.

The origin of the arsenic in the beer is obvious, when it is remembered that glucose is one of the substances commonly used in the brewing of beer, and that glucose is prepared by treating starch with sulphuric acid, which, is in turn, frequently made from iron pyrites containing arsenic.

After the source of the arsenic in the Manchester beer had been discovered, an arsenic “scare” set in. Every possible description of food was examined, and traces of arsenic were found in many hitherto unsuspected places.

Malt, dried in kilns and allowed to come in contact with the fumes from coal, invariably contains an appreciable amount of arsenic derived from the coal, and even malts prepared with the greatest care usually contain about one part per million of arsenic. For all practical purposes, however, so small a trace is negligible.

The members of the Royal Commission which was appointed to examine and report on arsenic in food were strongly divided with regard to whether any trace of arsenic should be permitted in food. Some were in favour of absolute prohibition, while others recognised that, even if this were done, the rule could never be rigidly enforced. Hence their report bears evidence of a compromise, for it states that although the Commission had been unable to discover that such minute traces of arsenic were injurious, yet they were unwilling to admit that any quantity, however small, was permissible in food.

Subsequently they recommended that a particular test should be used which would ensure that arsenic in food and drugs should not exceed an infinitesimal trace, and that frequent tests of raw and finished materials should be made.

These recommendations are now widely adopted, and it is highly improbable that another epidemic of arsenic poisoning will ever occur again in this country.

No better illustration of the vicious circles in which adulteration may move can be found than in the practice of certain manufacturers of jam of the cheaper kind. Apple pulp is a common constituent of jams which conceal their identity under another name. Now, in the case of raspberry jam, for example, it is necessary to have the seeds as well as fruit pulp, and these seeds may be bought very cheaply from the makers of fruit essences.

The best quality of these essences is prepared by mixing the fruit with alcohol and distilling the mixture, the spirit carrying over with it the ethereal oils to which the fruit owes its characteristic odour and flavour. Cheaper fruit essences are imitated chemically by making the most important of the compounds in the genuine ethereal oils, and dissolving them in spirit; but they are usually coarse in flavour, and do not bear comparison with the real product. Where intermediate grades are wanted, mixtures of the real and synthetical essences are often blended, and these frequently imitate the natural product so closely as to be only distinguishable by a trained sense of smell and taste.

In the preparation of the genuine fruit essences a residual pulp, containing the seeds and woody fibre of the fruit, but devoid of all flavour or aroma, is left behind, and it is this which the unscrupulous jam manufacturer makes use of in preparing a cheap jam, in which the seeds, at all events, are genuine. Then, in order to give more flavour to his product, he buys from the essence maker a flavouring essence, a small part of which may have originally been derived from the fruit that has given him the pulp and seeds for his jam.

The question of adopting a fixed standard for all natural products is one that has been widely discussed. It would have the advantage of simplifying the issue to be decided by the analyst and of preventing possible errors of judgment in the case of samples upon the border line between undoubtedly genuine and undoubtedly adulterated products. On the other hand, the legal fixing of a standard gives security to a skilful adulterator, who is able to make his goods fall within the limit of the figures given by genuine products of low quality.

Although most of the milk in large towns consists of the mixed products of many herds of cows, and thus tends to have a percentage of fat only slightly higher than that required by the law, there is but little doubt that a considerable proportion is scientifically watered and thus brought down to a limit of richness, which is only a little above that which will enable it to pose as milk straight from the cow.

Another instance of this effect of standardisation was seen in Bavaria, where a few years ago a minimum analytical figure was fixed for lard, with the result that the American lard merchants sent to Germany large quantities of lard which answered the requirements of this test, but were heavily adulterated with beef fat.

However much an analyst may deprecate the fixing of standards for such products as milk and butter, he is forced in practice to fix a standard for himself. The Society of Public Analysts, recognising this, passed a resolution that milk to be regarded as genuine must contain not less than 11½ per cent. of solid matter, and of this not less than 3 per cent. must be fat.

This fixes the standard for milk at a very low limit, and undoubtedly leaves a margin for the watering of rich milks.

On the other hand, Dr. Vieth, whose experience in the examination of milks was probably unequalled, wrote in reference to this standard: “I think it is very judiciously fixed, but in upholding the standard of purity, it should never be forgotten that the cows have never been asked for nor have given their assent to it, and that they will at times produce milk below standard. A bad season for haymaking is, in my experience, almost invariably followed by a particularly low depression in the quality of the milk towards the end of the winter. Should the winter be of unusual severity and length, the depression will be still more marked. Long spells of cold and wet, as well as of heat and drought, during the time when cows are kept on pasture, also unfavourably influence the quality and, I may add, the quantity of milk.”

Mr. H. D. Richmond, who had also had the opportunity of examining an immense number of samples of milk, considered that the standard of 3 per cent. of fat was a reasonable one for the mixed milk of a whole herd, but considered that milk ought not to be pronounced as watered unless the solids other than fat were well below 8·0 per cent., except upon evidence derived from other tests.

In the Sale of Food and Drugs Act of 1899 powers were conferred upon the Board of Agriculture to make regulations determining what deficiency in the proportion of constituents of milk, cream, butter, or cheese should raise a presumption that the product was not genuine until the contrary was proved. Acting under this section of the Act, the Board adopted the minimum limit of the Society of Public Analysts, so that now any milk containing less than 3 per cent. of fat and 8·5 per cent. of cream is regarded as adulterated unless it can be proved by the vendor that it is genuine, and it thus has the effect of transferring the burden of proof from the prosecution to the defence.

As was mentioned above, the whole tendency of recent legal decisions is towards enforcing this standard. For instance, in a case in which there had been “an appeal to the cow,” it was held by the present Lord Chief Justice that: “If, however, the article produced, although it is produced by the cow, is the result of an abnormal condition of things arising either from disease, or, as here, from unsound treatment of the cow, I think that does amount to evidence upon which the magistrates can find the article is not of the nature, substance, and quality of the article demanded.”

A want of system characterises the whole administration of the Food and Drugs Act, and many of the local authorities are unwilling to see that an adequate number of samples are taken.

For instance, only a few years ago, Lancashire, with a population of over a million and a half, was content with 1,755 samples, or one to each 10,000 people, while in Essex, with a population of over half a million, the samples taken were 686.

In Bury St. Edmunds no samples at all were taken during the four years ending 1899, and a similar lax administration of the law in many other places might be cited.

Some places pride themselves upon their freedom from adulteration, because out of the paltry number of samples taken by the inspectors, a quarter of the number or less may have been adulterated.

Even when the limited number of samples is properly taken, there is often a scandalous inadequacy and frequent inequalities in the amount of fine inflicted.

For instance, a milkman was fined one shilling at Margate for the sale of watered milk—a fine grossly inadequate to take away temptation; while in other courts we find fines of a pound or more imposed for exactly the same offence.

The remedy for this would be to have a fixed scale of fines for each offence. Another direction in which legislation is needed is the protection of the middle-class buyer. At the present time a shopman runs little or no risk in selling adulterated food to private houses. And the greater the vigilance of the local authority in protecting the buyer over the counter, the greater is the temptation to the shopkeeper to make an illicit profit out of ordered goods. Some means might well be provided for the examination of purchases in transit.

As a rule, the public is apathetic in the matter of adulteration, and errors of judgment, frequently inevitable under the present system, on the part of the analyst have led to his being regarded as the natural enemy of the tradesman.

If some system of standardisation for food products were generally adopted, leaving the burden of proof of the genuineness of abnormal samples upon the seller, and if the element of chance in the administration of the law were reduced, this prejudice on the part of tradesmen in general would disappear, although with the dishonest dealer the public analyst would become more unpopular than in the past.