It is an amazing fact that this country is one of the few that have not adopted a comprehensive system of food standards, but has relied on the administration of general provisions as to the purity of food; and it has been evident to officers engaged in enforcing these provisions that they were inadequate to deal effectively with all the cases in which foodstuffs of inferior quality were offered for sale to the public. Local authorities and courts of law have probably done their best within the limits of their legislative power to prevent as far as possible the sale of such foodstuffs, particularly where public health was endangered or there has been gross adulteration, but the subtlety of food adulteration in recent years has given rise to so much controversy as to how far the existing legislation has been contravened that the Minister of Health should be asked at the earliest opportunity to exercise the powers given to him in Section 8 of the Food and Drugs Act, 1938, to draft regulations as to the importation, preparation, storage, sale, delivery, etc., of food, and to include in such regulations a comprehensive system of food standards. There is ample evidence available for the consideration of any committee which might be appointed to draft the regulations. In 1901 a Departmental Committee of the Local Government Board, which had for two years been inquiring into the use of preservatives and colouring matter in food, recommended inter alia the prohibition of formaldehyde or copper salts in food, the limitation of boric acid to 0·25 per cent. in food, and the amount of salicylic acid not to exceed one grain per pound in solid food and one grain per pint in liquid food. There is also the Final Report of the Departmental Committee, 1924, which led to the introduction of the Public Health (Preservatives, etc., in Food) Regulations, 1925–27, which contained provisions limiting the use of preservatives to certain articles of food, prescribing the preservatives which could be used (sulphur dioxide and benzoic acid in specified amounts) and prohibiting the use of a number of metallic, vegetable and coal‐tar colouring matters. More recent still is the Report of the Departmental Committee appointed in 1933 to consider whether it was desirable that the law relating to the composition and description of articles of food should be altered so as to enable definitions or standards to be prescribed, or declarations of composition to be required for articles of food other than liquid milk, and if so to recommend what alterations of the law were required. As a food officer I was impressed on reading this report at the very wide field covered by the Committee in its search for evidence on the many aspects of the problem, and commend its perusal to all who are interested in the subject of food standards. Professional associations, traders' associations, associations of local authorities, scientists, doctors, public analysts, sanitary inspectors and trade representatives submitted their respective views. The report extends over several pages, but, briefly, the Committee were of opinion that it was not practicable to extend standards of definitions to all articles of food, that housewives would not benefit by a multitude of standards, definitions or declarations of composition, as in a large number of cases they were getting articles of the nature, substance and quality demanded, and that no standards or definitions should be laid down and no declaration of composition required without giving the manufacturers or other persons concerned the fullest opportunity of hearing the proposals and submitting their observations. The Committee also recommended that the contamination of articles of food by arsenic, lead, tin, or other impurities which may be contaminated in the process of collection or preparation should be treated as a special question. A further recommendation that specific claims made in advertisements should be deemed to be part of the package label has since been provided for in the Food and Drugs Act, 1938 (Section 6). In their evidence before the Departmental Committee in 1933, the Society of Public Analysts advocated the institution of a comprehensive system of standards and definitions, which would ultimately embrace all articles of food, and as this goes much further than the recommendation of the Committee, the views of public analysts on any new draft regulations will no doubt be awaited with considerable interest. In any case, their observations should be of considerable value when food standards are under consideration. Many suggestions for standards have emanated from commercial interests, and the Chief Medical Officer to the Ministry of Health, in his report for 1938, referring to these suggestions, stated “there is often discernible a desire to stifle competition, and that frequently the grade or qualities to which objection is taken are sound, wholesome articles of food, the suppression of which would be a distinct loss to the poorer class of consumers. New standards should therefore apply to all grades and not only to the higher‐grade articles. In fact, if any preference is to be shown it should be in respect of the cheaper grades. Where there is doubt of the efficiency of applying a standard, the desire should rest not on whether it will create difficulties in manufacture, although, of course, this aspect must be considered, but whether it is in the public interest that a standard should be laid down.” The Chief Medical Officer is to be commended for this timely warning, and it should be borne in mind by those drafting new regulations. It should be ensured that public welfare and not commercial interests should receive first consideration in a matter of this kind. There are many articles of food to which standards of composition are already applicable, including butter, margarine, condensed milk, dried milk, whisky, spirits, etc. There are also presumptive standards for milk and skimmed milk, and semi‐official standards for jam, vinegar and shredded suet. I am aware that under emergency powers the Ministry of Food have introduced standards for numerous articles of food, but these have been primarily introduced in connection with food rationing and other difficulties in connection with war‐time control of the principal foodstuffs. They are no doubt related to the availability of supplies of the various constituents, and therefore subject to alteration from lime to time, as instanced by the reduction in the percentage of meat to be contained in sausages. Except, therefore, as an experiment, these standards cannot be regarded as a satisfactory system, and will probably be revoked immediately the national situation justifies such a course being taken. We should not, therefore, be unduly influenced by these war‐time standards. Despite the desire of public analysis and food officers to have legal standards for all articles of food, it may be found impracticable to fix standards of composition for such articles as meat, fish, fruit, vegetables, eggs, etc., as they are prepared with the minimum of handling and are less likely to be adulterated. There are, however, many articles of food for which at present there are no legal standards as to their nature, substance or quality, and to which such standards might easily be made applicable, such as meat‐paste or fish‐paste, for which you have no guarantee of the percentage of meat or fish present. Just before the war there was a popular demand for cheese‐spreads, some of which contained up to 35 per cent. fat, but in the absence of legal standards varieties of cheese‐spreads may contain much less fat. There is no legal standard for cheese, with the result that whether it is made from skim milk or new milk it may still be sold as cheese. Mixtures of cocoa with starch and sugar may be sold as cocoa, if the fact that they are mixtures (without disclosing the percentage of cocoa) is disclosed on the label. In America milk chocolate must contain a minimum of 12 per cent. milk solids, but there is no such standard in this country. Although there is a bacteriological standard for ice‐cream in the Isle of Man, to the effect that when examined within twenty‐four hours of sale it shall not contain more than one hundred thousand bacteria per cubic centimetre, and no Baccilus coli in one‐tenth of a cubic centimetre, there is no such standard in this country. It has been suggested that ice‐cream should be made from milk, cream and sugar, with or without eggs, and contain a minimum of 8 per cent. of milk fat. An article sold as honey should be solely the product of the honey bee and not a chemically prepared substance. The latter might be designated as “artificial honey,” and labelled accordingly. Fruit juices should be what the name implies, and be manufactured and sold in compliance with statutory requirements. There should be standards for cordials, squashes, jams and preserves. Meat extracts should be made from good muscle fibre and its total creatine content slated on the label. If low‐grade meat is used, including offal, the fact should be disclosed on the label. With regard to statutory declarations on labels, the printing should be of such size that it is easily legible. It should neither be impossible nor impracticable to introduce legal standards for custard powders, baking powders, blancmange powders, pudding mixtures, cake mixtures, and many other foodstuffs which are ordinarily consumed by the public, not forgetting sweets and confectionery, wines and cocktails, milk shakes, and soft drinks. The ramp which went on during 1940–42 in connection with the sale of “food substitutes” was a striking example of the need for statutory standards of composition. It is often contended that if housewives only purchased goods prepared by reputable firms they would receive satisfaction, and while to a large extent this may be true, the fact remains that inferior articles still find their way into shops. There is, of course, the possibility that shopkeepers may be tempted by the offer of a larger margin of profit on goods supplied by firms of less repute. Some shopkeepers even fail to obtain a warranty that the goods supplied to them conform to the requirements of the Food and Drugs Act and Regulations. It is not sufficient for the Departmental Committee to state “that in a large number of cases housewives get articles of the nature, substance and quality demanded,” and leave it at that. An effort should be made to apply standards to every article of food to which the application of such standards is possible. Housewives should no longer be tempted or misled by catch advertisements, attractive labels or wrappings, or the inducement of free gifts. To give some idea of the need for a wider application of standards, a few cases dealt with during the past three years, some of which came under my own personal investigation, are set out below, with the Public Analyst's comments: 1.—Egg substitute.—Contained no true substitute for eggs; consisted of a solution of synthetic gum, probably made by treating cotton with some chemical; containing only 3·8 per cent. solid matter, the rest being water; had no food value.
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