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The Food and Drugs Bill introduced by the Government affords an excellent illustration of the fact that repressive legislative enactments in regard to adulteration must always be of such a nature that, while they give a certain degree and a certain kind of protection to the public, they can never be expected to supply a sufficiently real and effective insurance against adulteration and against the palming off of inferior goods, nor an adequate and satisfactory protection to the producer and vendor of superior articles. In this country, at any rate, legislation on the adulteration question has always been, and probably will always be of a somewhat weak and patchy character, with the defects inevitably resulting from more or less futile attempts to conciliate a variety of conflicting interests. The Bill as it stands, for instance, fails to deal in any way satisfactorily with the subject of preservatives, and, if passed in its present form, will give the force of law to the standards of Somerset House—standards which must of necessity be low and the general acceptance of which must tend to reduce the quality of foods and drugs to the same dead‐level of extreme inferiority. The ludicrous laissez faire report of the Beer Materials Committee—whose authors see no reason to interfere with the unrestricted sale of the products of the “ free mash tun,” or, more properly speaking, of the free adulteration tun—affords a further instance of what is to be expected at present and for many years to come as the result of governmental travail and official meditations. Public feeling is developing in reference to these matters. There is a growing demand for some system of effective insurance, official or non‐official, based on common‐sense and common honesty ; and it is on account of the plain necessity that the quibbles and futilities attaching to repressive legislation shall by some means be brushed aside that we have come to believe in the power and the value of the system of Control, and that we advocate its general acceptance. The attitude and the policy of the INTERNATIONAL COMMISSION ON ADULTERATION, of the BRITISH FOOD JOURNAL, and of the BRITISH ANALYTICAL CONTROL, are in all respects identical with regard to adulteration questions; and in answer to the observations and suggestions which have been put forward since the introduction of the Control System in England, it may be well once more to state that nothing will meet with the approbation or support of the Control which is not pure, genuine, and good in the strictest sense of these terms. Those applicants and critics whom it may concern may with advantage take notice of the fact that under no circumstances will approval be given to such articles as substitute beers, separated milks, coppered vegetables, dyed sugars, foods treated with chemical preservatives, or, in fact, to any food or drug which cannot be regarded as in every respect free from any adulterant, and free from any suspicion of sophistication or inferiority. The supply of such articles as those referred to, which is left more or less unfettered by the cumbrous machinery of the law, as well as the sale of those adulterated goods with which the law can more easily deal, can only be adequately held in check by the application of a strong system of Control to justify approbation, providing, as this does, the only effective form of insurance which up to the present has been devised.

The year 1820 was a landmark in the story of adulteration for in that year was published “A Treatise on the Adulteration of Food, and Culinary Poisons, etc., etc.” by Dr. F. Accum. The first edition of 1,000 copies was sold in a month and a second edition was at once printed. The preface to this second edition says that the author had received a number of anonymous communications containing maledictions and menaces. The book says, “it would be difficult to mention a single article of food which is not to be met with in an adulterated state ; and there are some substances which are, scarcely ever to be procured genuine.” He records that butchers meat and fish were blown by means of a quill or the stem of a tobacco pipe to make the flesh appear firm and glistening. The water used in London came from the Thames which received all the contents of the sewers, drains and water‐courses. He says that no water becomes putrid sooner than that of the Thames, smelling of carburetted and sulphuretted hydrogen gases. Sawdust was used for increasing the stringency of wine and this was supplied by wholesalers to the brewers' druggist as an ordinary article of commerce. Old and stale beer which had gone acid was converted to mild by using oyster shells to neutralise the acid. He states that the detection of adulteration of beer with deleterious vegetable substances is beyond the scope of chemical science ; but within about 20 years methods were available for them. Most lozenges were kept in two grades, the cheaper at half the price being “reduced,” as it was called, with clay, sugar, pepper or other spices. With regard to wine‐brewers he quotes from “The Tatler” of 1797: “There is in this city a certain fraternity of chemical operators who work in underground holes, caverns and dark retired spots to conceal their mysteries from the eyes and observations of mankind. These subterranean philosophers are daily employed in the transmutation of liquors and of the power of magical drugs and incantations, raising under the streets of London the choicest products of the hills and valleys of France. They can squeeze Bordeaux out of the sloe and draw Champagne from an apple.” He records how bottles were “Crusted,” i.e. the interior of empty wine bottles were lined with a red crust to imitate the deposit from wine ; a factitious product was added and the bottles closed with corks having the lower part dyed a fine red as if they had long been in contact with wine. With regard to tea he records how different varieties of leaves from trees and shrubs were first boiled and then baked on an iron plate. When dry they were coloured and rubbed in the hand to produce a curl resembling that of genuine tea. To obtain a green variety, the leaves were coloured with verdigris. Usually the sloe leaf was used. Accum suggested that the housewife could take her part in detecting false teas and said “Our ladies are our teamakers ; let them study the leaf as well as the liquor ; let them become familiar with both vegetables, with their forms, colours, flavours and scents ; let us drink our tea upon the responsibility of our wives, daughters and sisters, and not upon that of our grocers. Let every female distinguish tea leaves from sloe‐leaves, as well as if she had served an apprenticeship in the warehouse in Leadenhall Street.” The reason for the prevalent adulteration of tea was the heavy revenue duties. Spices were also heavily dutied and expensive, and nearly all were adulterated. The pepper duty was 2s. 6d. a lb. and factitious pepper berries were made from linseed cake, clay and cayenne pepper. Accum wrote several books on food technology and did a lot of useful work by lecturing on adulteration ; but probably his greatest service was drawing attention to the dangers from poisoning by metallic compounds either added as colouring matters or introduced accidentally by the use of unsuitable metal containers. These hazards were generally caused through ignorance. For example in “The Falsification of Food” by Mitchell there is an account of an investigation of poisoning by Gloucester cheese. A man was taken seriously ill at an inn and some observant person noticed that a cat became violently ill after eating the rind of the Gloucester cheese which the man had left. The cheese was examined and found to contain large quantities of lead. The manufacturer of the cheese was unable to account for it as he was certain of the purity of his own materials and had purchased the annatto, with which it was coloured, from a reputable firm. This firm was certain that the annatto supplied consisted solely of genuine annatto, improved in colour with vermilion, a normal practice in the trade. On further enquiry it was found that the druggist who had sold the vermilion had assumed it would only be used as a pigment for house painting and had mixed it with red lead to increase his profit and without any suspicion that harm could come of it. The investigator says “Thus through the circuitous and diversified operations of commerce a portion of deadly poison may find admixture into the necessities of life in a way which can attach no criminality to the parties through whose hands it has successively passed.” Although it has been known for over 2,000 years that lead salts were violent poisons, it was for long assumed that metallic lead was insoluble in water and fruit juices. It was a common practice for proprietors of wells to instruct plumbers to use double the thickness of lead because it was known that the local water corroded the lead very quickly. No one had troubled to wonder what became of the corroded metal. A gentleman had 21 children of whom eight died in early infancy. Both parents and the remaining children were remarkably unhealthy, being particularly subject to stomach disorders. The father became paralytic and the mother was continuously subject to colic. When the parents died the house was sold and the children moved ; they immediately improved in health. The purchaser of the house found it necessary to repair the pump and found it so corroded that the cylinder was perforated in several places and the cistern was reduced in thickness to that of brown paper. Too late the cause of years of trouble was discovered. Accum's treatise aroused attention in scientific circles and several other workers investigated food, among whom may be mentioned Mitchell, Normandy, Chevalier, Garner and Harel. But the general public did not read their scientific books. Shortly afterwards there appeared anonymously a small brochure under a long title but generally referred to as “Death in the Pot.” This was written in popular style, had a large sale and a great influence on the public. The immediate result was a wide circulation of knowledge of adulteration and contamination of food and both were generally condemned. A writer expressed the opinion that the life of man would generally be extended to 100 years were it not for his excesses and the adulteration of his food. As regards adulteration the public could do little to prevent it; but the effects of contaminated food being rapid, the people could complain to the sellers and for their own sakes manufacturers were compelled to scrutinise the materials used and to discard colouring matters and metallic utensils which they knew to be dangerous. It has previously been mentioned that Excise Officers were concerned with adulteration in connexion with articles subject to a revenue duty. Tobacco was a source of considerable revenue and the Excise were ever on the watch against adulteration. An Act of 1840 had prohibited the mixing of tobacco with a number of substances but the effect was to increase adulteration with others. One of the Excise Officers, George Phillips, had in his spare time become proficient in chemistry and in the use of the microscope, and he offered his services to the Commissioners of Excise for the particular purpose of examining tobacco for purity. This was eventually agreed to and in 1842 Phillips was given a room for his purpose. His success was immediate and his activities were soon extended to other excisable materials including a variety of foods. This one man and one room eventually became the Inland Revenue Laboratory, Somerset House, which was subsequently constituted into a separate Department known as the Department of the Government Chemist. Its activities now extend to work for all Government Departments, but the original objects for which it was founded over 100 years ago still form an important part of its work. By 1850 the public had become hygiene‐conscious, largely due to the pioneer work of such men as Chadwick, who had been calling attention to unsound and unhealthy conditions in all forms of sanitary services. In that year the “Lancet” established “The Lancet Sanitary Commission” to institute an extensive series of investigations into the condition of various articles of diet supplied to the people. A leading spirit of the Commission was Dr. Hassall who did much experimental work in the examination of commercial foods sold to the public and reported his findings in the “Lancet.” In 1855 he published “Food and its Adulterations, comprising the reports of the Analytical Sanitary Commission of the Lancet for the years 1851–1854.” Hassall exploited the microscope in the detection of adulteration and recorded many pictures of the microscopic characteristics of vegetable foods and adulterants. Without the more refined methods of today he was able to detect adulteration in a very large proportion of the samples examined. For example:—

The following report was brought up by Dr. P. Brouardel, Dean of the Faculty of Medicine of Paris, President of the Commission, and was submitted for the approval of the Congress:

Consumption of game meat is growing when compared to other meats. It is susceptible to adulteration because of its cost and availability. Spectroscopy may lead to rapid methodologies for detecting adulteration. The purpose of this study is to detect the adulteration of wild fallow deer (Dama dama) meat with domestic goat (G) (Capra aegagrus hircus) meat, for samples stored for different periods of time using Fourier transform infrared (FTIR) spectroscopy coupled with chemometric.

Meat was cut and mixed in different percentages, transformed into mini-burgers and stored at 3°C from 12 to 432 h and periodically examined for FTIR, pH and microbial analysis. Principal component analysis (PCA) and partial least squares discriminant analysis (PLS-DA) were applied to detect adulteration.

The PCA model, applied to the spectral region from 1,138 to 1,180, 1,314 to 1,477, 1,535 to 1,556 and from 1,728 to 1,759 cm⁻¹, describes the adulteration using four principal components which explained 95 per cent of variance. For the levels of Adulteration A1 (pure meat), A2 (25 and 50 %w/wG) and A3 (75 and 100 %w/wG) for an external set of samples, the correlation coefficients for prediction were 0.979, 0.941 and 0.971, and the room mean square error were 8.58, 12.46 and 9.47 per cent, respectively.

The PLS-DA model predicted the adulteration for an external set of samples with high accuracy. The proposed method has the advantage of allowing rapid results, despite the storage time of the adulterated meat. It was shown that FTIR combined with chemometrics can be used to establish a methodology for the identification of adulteration of game meat, not only for fresh meat but also for meat stored for different periods of time.

The adulteration of food has progressed from being a simple means of fraud to a highly sophisticated and lucrative business. The problem is further compounded by the lack of clear international definitions for enforcement purposes. Reviews some examples of food adulteration and methods of analysis used to determine authenticity. Adulteration of food has ramifications within society and cannot be ignored since interference with foodstuffs may potentially lead to the production of food which is harmful to health.

Adulteration is the wilful addition to an article of any substance or substances the presence of which is not acknowledged in the description under which the article is sold, or the abstraction from an article of an essential constituent without disclosing that it is impoverished. Some common synonyms are: corruption, defilement, debasement, vitiation and sophistication, all of which indicate the sinister nature of the act. Articles are adulterated to increase their weight or bulk, and to improve or change their appearance or flavour in imitation of an article of higher grade or different kind. In the limiting case it can be regarded as covering the complete substitution of one article for another. Wilful addition implies addition which could have been avoided and hence covers contamination brought about by lack of care. The term is used mainly in connexion with foods and drugs, but in practice extends to almost all manufactured products and is an almost inseparable accompaniment of trade competition. It will be observed that there are two requirements for adulteration, viz. an action and an intention. The mere act of mixing one thing with another does not, in itself, warrant the term adulteration. It must be coupled with an intention to deceive by passing off the mixed article as if it were unmixed. The intention is usually not apparent until some circumstance warrants the inference, such as the sale or exposure for sale of the article. The inclusion of such concepts as wilfulness and intention, which are much more difficult to prove than facts, introduces difficulties and prevents in practice the employment of a simple definition without provisions being made to protect the honest man from injustice. Accidental contamination or impurities unavoidably present, if not due to neglect or lack of reasonable care, are not normally regarded as adulteration unless the impurity is dangerous to health. In this country the only law which deals directly with adulteration is the Food and Drugs Act. The present Act, that of 1938, prohibits :—

The desire to obtain authentic guidance as to the real nature, quality and value of food‐products and of other articles of necessity has grown rapidly during recent years, while the demand for amending and additional legislation, and for increased governmental and official activity, plainly indicates that general public attention to this most important of national questions is at length aroused.

The subject dealt with in this paper is one of very wide scope, and is surrounded by many difficulties—scientific, legal, commercial and social. Its aspects are many and various, its subsidiary ramifications are widely extended and often highly complicated, and it is impossible, within the narrow limits of a single paper or lecture, to do more than sketch out its main features in a manner that will enable the general public to appreciate their significance and relative importance.

The Food Bill has emerged from the Grand Committee on Trade, and will shortly be submitted, as amended, to the House of Commons. Whatever further amendments may be introduced, the Bill, when passed into law, will but afford one more example of the impotence of repressive legislation in regard to the production and distribution of adulterated and inferior products. We do not say that the making of such laws and their enforcement are not of the highest importance in the interests of the community; their administration—feeble and inadequate as it must necessarily be—produces a valuable deterrent effect, and tends to educate public opinion and to improve commercial morality. But we say that by the very nature of those laws their working can result only in the exposure of a small portion of that which is bad without affording any indications as to that which is good, and that it is by the Control System alone that the problem can be solved. This fact has been recognised abroad, and is rapidly being recognised here. The system of Permanent Analytical Control was under discussion at the International Congress of Applied Chemistry, held at Brussels in 1894, and at the International Congress of Hygiene at Budapest in 1895, and the facts and explanations put forward have resulted in the introduction of the system into various countries. The establishment of this system in any country must be regarded as the most practical and effective method of ensuring the supply of good and genuine articles, and affords the only means through which public confidence can be ensured.

The Daily Telegraph has recently published several articles and a considerable amount of correspondence relating to malt whisky and the tricks of the whisky trade. As is usually the case when a daily newspaper takes up a subject of this kind, a number of well ‐ meaning people make a variety of suggestions as to what ought to be done to secure the purification of the particular Augean stable under discussion and to ensure the reception by the purchaser of the article which he really desires to have. But what ought to be done and what can be done are two very different things, and the question of what it is possible to do in the present state of scientific knowledge—and under the existing law as it is at present administered— is, as a rule, avoided by the writers referred to. It has been suggested, for instance, that it should be made compulsory that all vessels in which spirits are sold should bear a label distinctly stating the exact nature of the contents of such vessels. This would be an excellent suggestion if it could be effectively carried out, but, before this can be done, it is necessary to devise a method of compulsion. A man who sells as malt whisky an article mainly or entirely composed of spirit to which that title should not be applied would not have any very serious scruples as to the truth of the statements which appear on his labels. He must be compelled to act honestly by some sufficient force, and, short of a law which would permit the manufacture and “blending” of whisky to be carried out by certain persons only, according to specified rules, and under strict Government supervision in every case, no legislative enactments whatever would have the effect of preventing the various forms of this particular fraud. At present there are no legal definitions whereby the composition and characters of the articles described as “malt whisky” and “whisky” are laid down, excepting the definitions which may be held to be implied in the application of the 6th section of the Sale of Food and Drugs Act of 1875 to the case. This section requires that an article shall be of the “nature, substance, and quality demanded by the purchaser.” On the strength of this section it is quite unjustifiably assumed that the compulsion referred to can be effectively secured by the operation of the Sale of Food and Drugs Acts. According to our legal system it is essential under the criminal Acts— and the Food Adulteration Acts are criminal Acts—for the prosecuting authority to prove beyond all possibility of question that a person charged with an offence is guilty of that offence, and, in regard to the matter under consideration, it would therefore be necessary to absolutely prove by scientific evidence that any given mixed spirit, for the sale of which as malt whisky a prosecution had been instituted, was not of the nature, substance, and quality of the article demanded. Under the present conditions relating to sampling under the Acts this would be impracticable, except, possibly, on very broad lines; and, assuming that scientific investigation resulted in the possibility of fixing clear and definite points of distinction between the true and the false, there would still be the enormous difficulties and the heavy expenses attending the proving of offences of this character to the satisfaction of the Courts—difficulties and expenses which local authorities cannot fairly be expected to face. If, after the lengthy and expensive investigations that would be necessary, and which could only be properly carried out with Government aid, by a scientific Commission appointed by the Government, it were found possible to establish working definitions and standards, these would necessarily be only applicable to a limited extent, just as is at present the case in regard to milk and butter; while the question of quality can never be dealt with under repressive Acts of, Parliament of any kind. Assuming the establishment of standards of some kind we fully admit the possibility, under altered legal conditions, of checking the grosser forms of whisky sophistication by the employment of legal machinery, as is done with various other products; but vast amounts of various spirit mixtures could still be sold under false names with impunity. We should still have with us the legalised inferiority and the legalised adulteration of comparatively minor type which we have in the case of milk and butter. What is required and what alone can be effective, in dealing with sophistications which the law can never reach, is the provision of adequate and entirely independent guarantees which are based both on permanently‐applied analytical investigations carried out upon quantities of material which are not absurdly limited, and on a system of permanent and independent inspection,—both being supplied by some authority or authorities of sufficient standing. While the statements made by a reputable firm ought to carry weight, and ought, no doubt, to be accepted as valuable so far as they go, there is always necessarily and obviously a great element of weakness in the declarations put forward by a firm with respect to its own products. Particularly in view of modern commercial conditions something very much stronger than a personal asseveration as to the purity and excellence of one's own goods is now in reality required. That this is the case is shown by the fact that the demand for independent guarantees has recently been repeatedly voiced in the general press. The public are badly in want of education on all such questions and the Daily Telegraph is entitled to the thanks of the community for having initiated a discussion which can only be productive of good results in this direction.