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I am directed by the Local Government Board to request the attention of the council to the subject of the addition of preservatives to milk..

A serious objection to the use of preservatives in milk has been pointed out in the report of the departmental committee on preservatives and colouring matters in food who state that preservatives in milk "may be relied on to protect those engaged" in the milk traffic "against the immediate results of neglect of scrupulous cleanliness. "Under the influence of these preservatives milk may be exposed "without sensible injury to conditions which otherwise would render "it unsaleable. It may remain sweet to taste and smell and yet "have incorporated disease germs of various kinds, whereof the activity may be suspended for a time by the action of the preservative, but may be resumed before the milk is digested."

66

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This committee, after hearing evidence from milk traders, concluded that the addition of a preservative to milk is not necessary for the purposes of the milk trade, even in hot weather or where the supply of so large a place as London is concerned, and the committee recommended that no preservatives should be added to milk.

In making this recommendation the committee had special regard to evidence received as to two classes of preservative substances which, under various names, are frequently used as preservatives in milk, viz. (1) formalin (a 40 per cent. solution of formic aldehyde) and other preparations of formic aldehyde; and (2) boron preservatives (boric acid, borax, or mixtures of boric acid and borax). The committee considered that the addition to milk of formalin or preparations of formalin, even when the amount which could be detected was minute, was objectionable, on account of the alterations effected by formalin in the character of certain of the constituents of milk and of its ability to interfere directly with digestive processes.

Although in the view of the committee boron preservatives might reasonably be employed in the case of certain foods, within defined limits and subject to a declaration as to their presence and amount, the committee recommended their exclusion from milk altogether; partly for the reasons above indicated, and partly also in consideration

1906.

Circular, of the immense importance of pure milk for the nutrition of infants, 11th July, invalids, and convalescents, and of the comparatively large quantity of milk which may be taken, particularly by children, in comparison with the other foods in question. Moreover the committee had evidence "pointing to an injurious effect of boracised milk upon the "health of very young children."

Since the report of the committee was made the Board have from time to time had before them further evidence on the subject, and this supports the conclusions of the committee not only as to the objections to the use of preservatives on the ground of public health, but also as to the ability of milk traders to conduct their business without use of preservatives. Thus in certain boroughs in London and elsewhere in which milk samples are systematically tested for preservatives, the presence of preservatives in milk, at any time of the year, has been found to be exceptional; and there is evidence to show that a very large number of milk vendors conduct their business without the use of these substances, even where the milk comes long distances by rail.

In some districts action under the Sale of Food and Drugs Acts has been frequently and successfully taken in order to bring about the disuse of preservatives in milk. Proceedings instituted against vendors of milk containing preservatives have usually been taken under section 6 of the Sale of Food and Drugs Act, 1875. Conviction has followed, it being held that when the purchaser who asks for milk is supplied with milk plus a preservative he does not receive an article of the nature substance and quality demanded, and is prejudiced thereby.

The Board are of opinion that action under the Sale of Food and Drugs Acts in regard to preservatives in milk is desirable, and that this subject deserves attention from all authorities in England and Wales charged with the execution of these Acts.

In this connection the following suggestions are made for adoption by the council where a similar procedure is not already followed :

1. Information from public analysts.

The Board suggest that public analysts should be requested
(a) to record in their quarterly reports how many milk samples
have been examined during the quarter with a view to ascer-
taining the presence of substances commonly in use as
preservatives, and with what result; and to draw the attention
of the council to instances where the use of preservatives
in milk other than boron preservatives and formalin have
come under notice;

(b) to report, on completion of analysis, the facts as to samples
of milk which have been found to contain any added
preservative.

2. Administrative action where preservatives in milk are reported.

The Board would suggest that the council should notify to milk traders, by circular or otherwise, that action will be taken under the Sale of Food and Drugs Acts in instances where preservatives are reported in milk.

Subject to this being done, and to exceptional cases of the kind referred to under the heading numbered 3 below, the Board consider that when the presence of any added preservative is reported in a sample of milk taken in accordance with the provisions of the Sale of Food and Drugs Acts, the case should in ordinary circumstances be regarded as one for the institution of proceedings under those Acts.

3. Declaration and Notices.

The Board think it desirable to draw attention to cases in which the vendor of the milk, with the object of escaping liability under section 6 of the Sale of Food and Drugs Acts, 1875, declares to the purchaser by means of a notice, label or otherwise that he does not sell "milk" as such, or that its quality in regard to preservatives or other constituents is not guaranteed, or that it contains some added preservative.

The Board would suggest the desirability of frequent sampling in cases where "milk" is sold subject to declarations of the kind, with a view to ascertaining the condition of such milk in regard to preservatives.

The nature of the declaration made should in all cases be carefully recorded by the officer taking the sample, and should also be reported to the analyst when the sample is transmitted for analysis.

Where preservatives are reported in milk thus sold, the question will arise whether, in view of the nature and quantity of the preservatives added, it can be considered that the article has been rendered injurious to health, or that the purchaser has been prejudiced, to an extent which would justify the institution of proceedings under section 3 or section 6 of the Sale of Food and Drugs Act, 1875, notwithstanding the declaration made at the time of purchase.

This question is not without difficulty in view of the general objection to the employment of any preservatives in milk referred to above.

As regards formalin and boron preservatives, however, the Board are advised that the presence in milk of formalin to an amount which is ascertained by examination within three days of collecting the sample to exceed 1 part in 40,000 (1 part in 100,000 of formic aldehyde)

Circular, 11th July, 1906.

1906.

Circular, raises a strong presumption that the article has been rendered in11th July, jurious to health, and that the purchaser has been prejudiced, in the above sense; and also that similar presumption is raised where boron preservatives are present in milk to an amount exceeding 57 parts of boric acid per 100,000, or 40 grains of boric acid per gallon.

It appears desirable that the addition of preservatives to skim milk, separated milk, and condensed milk, should be watched and con trolled on similar lines.

Additional copies of this circular are enclosed for transmission to the public analyst, and for use by executive officers under the Sale of Food and Drugs Acts. The circular will be placed on sale and copies can then be obtained from Messrs. Wyman & Sons, Limited, 109, Fetter Lane, Fleet Street, London, E.C., either directly or through any bookseller.

I am, Sir,

Your obedient Servant,

S. B. PROVIS,

Secretary.

The Town Clerk, or

The Clerk to the County Council.

UNEMPLOYED WORKMEN ACT, 1905.
Regulations: Organisation for Unemployed.

,183.

(Record Paper Amendment.)

13th January, 1906.

To every Central Body under the Unemployed Workmen
Act, 1905-

To every Distress Committee and to every Special Com-
mittee under that Act ;-

To the London County Council;

To the Councils of all other Administrative Counties ;--
To the Mayor, Aldermen, and Commons of the City of
London in Common Council assembled ;--

To the Mayor, Aldermen, and Councillors

Metropolitan Borough ;

of each

To the Council of every Municipal Borough or Urban
District to which the said Act applies;-

And to all others whom it may concern.

WHEREAS by the Regulations (Organisation for Unemployed), 1905, We, the Local Government Board, made provision with respect to the record papers to be provided and used in accordance with those regulations;

And whereas it is expedient that the form of the record paper be altered in certain particulars :

NOW THEREFORE, in the exercise of Our powers in that behalf, We hereby make the following regulations; that is to say,

Order,

13th Jan. 1906

ARTICLE I.—In these regulations, unless the contrary intention Interpretation.

appears

(a) The expression "the principal regulations" means the
Regulations (Organisation for Unemployed), 1905; and

(b) Other words and expressions have the same meaning as in

the principal regulations.

record paper.

ARTICLE II.—The principal regulations shall have effect as if for New form of the schedule' to the principal regulations there were substituted the schedule to these regulations; and, as if the record paper to be provided and used in accordance with the principal regulations were a record paper in the form set forth in the schedule to these regulations.

Commencement

Short title.

ARTICLE III.—These regulations shall have effect from and after of regulations. the first day of February, One thousand nine hundred and six. ARTICLE IV. These regulations may be cited as "the Amending Regulations (Organisation for Unemployed), 1906.”

1See Law and Legislation, 1905, pp. 65, 66,

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