very gratifying to find that none of the essayists produce any definite or satisfactory evidence as to the widespread existence of such dangerous adulterations in this country.

The absence of such evidence, in addition to the results recently obtained by several expert chemists in extensive series of analyses of the usual articles of food in this country, which results have been made known to the committee, fully warrants us in declaring that none of our staple articles of food or drink are so commonly adulterated as to be dangerous to health or life. Such dangerous adulterations appear to be mainly in the form of poisonous colours or colouring matters, as, for instance, in confectionery, and even these

are rare.

2. The question of the adulteration of food, with perhaps the exception of milk, should therefore be considered not so much from a sanitary standpoint as from that of commercial interests; as being of the nature of a fraud, in aiding the sale of articles which are not what they are represented to be. The main objects of legislation upon this subject should be to prevent deception, to furnish to the public authoritative information, and to nullify the operations of ignorant and sensational alarmists, who damage the business interests of the country quite as much as do the evils of which they complain.

3. We are of the opinion that there is much more danger to health and life in this country from adulterated drugs, than there is from adulterated food, and that any legislation which is to deal with the one should also deal with the other.

4. To indicate the legislation upon the adulteration of food and drugs, which will protect health and prevent fraud, and at the same time not impose unnecessary burdens upon trade is a matter of very great difficulty, as the result of this competition clearly shows, for we do not consider any of the Acts proposed to be satisfactory. In this matter it is much better at first to do too little than too much, and the first steps in such legislation should be tentative and educational in character.

5. While it is highly desirable that the general principles of legislation on this subject should be the same in all States, we do not think it possible to secure by State laws absolute uniformity in the details in all parts of this country, and it would therefore be unwise to make the attempt.

6. We do not think that any law upon the adulteration of food and drugs can be made efficient without a properly constituted health authority to supervise its execution. The questions involved are in a high degree technical, and require special training in those charged with administering the law. At the same time we think that the existence of such health authorities should be taken for granted in the Acts and that these should not attempt to create them.

We believe that every State should have a Board of Health, but that such Boards should be created by independent legislation.

7. We think it unadvisable that the law should attempt to define in detail as to what an adulteration is. A very considerable amount of discretion should be left to the Board of Health in this respect, limiting it only in the direction of possible over-rigidity. Many well recognized articles of commerce, although harmless and even useful, may be said to be adulterated, and it should be left to the discretion of the Board to exempt any article from the penalties imposed in the Act.

8. Care should be taken not to make the penalties excessive. It should be remembered that mere exposure of fraudulent practices, if effectually and persistently made, is in itself

a penalty, and as a rule public opinion may be trusted to make such practices unprofitable if measures be taken to make this opinion a correct one, which we think should be the great object of the law proposed.

Under no circumstances should fees or moieties to informers be allowed.

The

9. We think that both State and National laws upon this subject are desirable. State law should deal with the subject in the individual State. The National law should deal with adulterated articles coming from foreign countries, or passing from one State into another, and also with adulterations in the Territories, the District of Columbia, and in all places under the special jurisdiction of the United States. It is, of course, in the highest degree desirable that the State and United States legislation on this subject should not be discordant.

The educational feature should be even more prominent in the National than in the State law, while the punitive feature should, if anything, be less severe. As the State laws will vary somewhat in this last respect, it follows that the penalties in the United States law should be at a minimum.

10. The Committee will endeavour to prepare and to place in the hands of the President of the National Board of Trade as soon as possible drafts of Acts, prepared in accordance with the general principles contained in this report.

The Definition of an Adulterated Article, and the Principal Clauses of the Draft Act proposed in the Essay by Mr. WIGNER, are as follows:

An Article shall be deemed to be Adulterated within the meaning of this Act.

A. IN THE CASE OF DRUGS.

1. If, when sold under or by a name recognised in the U.S. Pharmacopoeia, it differs from the standard of strength, quality, or purity, laid down therein.

2. If, when sold under or by a name not recognised in the U.S. Pharmacopoeia, but which is found in some other Pharmacopoeia, or other standard work on Materia Medica, it differs materially from the standard of strength, quality, or purity laid down in such work. 3. If its strength, or purity, fall below the professed standard under which it is sold.

B.-IN THE CASE OF FOOD OR DRINK.

1. If any substance, or any substances, has, or have been mixed with it, so as to reduce, or lower, or injuriously affect its quality, strength, purity, or true value.

2. If any inferior or cheaper substance, or substances, have been substituted wholly, or in part, for the article.

3. If any valuable constituent of the article has been wholly or in part abstracted.

4. If it be an imitation of, or be sold under the name of another article.

5. If it consist wholly or in part of a diseased, or decomposed, or putrid, or rotten animal or vegetable substance, whether manufactured or not; or in the case of milk, if it is the produce of a diseased animal.

6. If it be coloured, or coated, or polished, or powdered, whereby damage is concealed, or it is made to appear better than it really is, or of greater value.

7. If it contain any added poisonous ingredient, or any ingredient which may render such article injurious to the health of a person consuming it.

LIMITS.

The following shall be deemed limits for the respective articles referred to :—

Milk shall contain not less than 90 per cent. by weight of milk solids, not fat, and not less than 2.5 per cent. of butter fat.

Skim milk shall contain not less than 9.0 per cent. by weight of milk solids, not fat. Butter shall contain not less than 80·0 per cent. of butter fat.

Tea shall not contain more than 8.0 per cent. of mineral matter, calculated on the tea dried at 100o C., of which at least 3.0 per cent. shall be soluble in water, and the tea as sold shall yield at least 30.0 per cent. of extract.

Cocoa shall contain at least 20 per cent. of cocoa fat.

Vinegar shall contain not less than 3.0 per cent. of acetic acid.

It will be seen that in the case of drugs sold under names found in the U.S. Pharmacopoeia, this definition allows of no deviation, either by increase or decrease of strength, quality or purity.

As to drugs not called official, it appears desirable to allow some slight variation, because different standard authorities do show slight discrepancies, and therefore, in that case, the words I have used are "differs materially."

AS TO FOOD AND DRINK.

The watering of milk is provided for by Nos. 1 or 2, the skimming of milk by No. 3, which also provides against the sale of partly exhausted coffee or tea. The sale of butterine under the name of butter by No. 4.

Milk from diseased cows, pickles made from rotten vegetables, or rancid or putrid butter are provided for by No. 5, and the refacing of tea or polishing of coffee and pepper, and the case of hams coloured externally with chromate of lead, &c., by No. 6.

The admixture of chicory with coffee, potato starch with arrowroot, damaged flour with sound flour, and other similar adulterations, are provided for by No. 2, and the undue watering of spirits by No. 1 or No. 2; and bad spirits containing large quantities of fusel oil, or beer containing "cocculus indicus," or other injurious constituents by No. 7, which also provides for the presence of lead or poisonous metals in tinned goods.

This definition is purposely drawn in the most stringent form, because all exceptions which should be made in order to prevent the Act from bearing with undue pressure upon honest tradesmen, or from hampering manufacturers, are the better made in the Act itself, and not in the definition.

The definition should meet every possible case of fraud or carelessness, and the Act must provide relief from its stringency wherever that relief is needed.

Appended to the definition, it will be desirable to have the table of limits, which may, perhaps, at a future time be extended with advantage, showing the degree of richness or quality required in certain articles. This should be inserted as a separate schedule to the Act, and power should be given to the State Board of Health, as provided in the draft Act,

to add to, take from, or alter these limits from time to time as may be found desirable, due notice being given to the public of any such alteration.

APPENDIX A.

PROPOSED DRAFT OF A NATIONAL ACT, BY MR. WIGNER.

An Act to Prevent the Adulteration of Food and Drugs, or the Sale of Adulterated Articles of Food or Drugs.

Whereas it is reported that adulterated or spurious articles of food and drugs are man ufactured, imported or sold within the United States; and also that damaged or diseased articles of food or drugs are manufactured, imported or sold; and whereas, in order to prevent injury to the public health, or fraud, injury, or prejudice or loss to the purchaser of such articles as those hereinbefore referred to, it is desirable to suppress such practices.

Be it enacted:

For the purpose of this Act the definition of an adulterated article shall be that which is given in Schedule A of this Act, and wherever an adulterated article is herein referred to the phrase shall be interpreted in accordance with that definition.

The term "food" shall include every article used for food or drink by man, except water.

The term "drug" shall include all medicines for internal or external use.

State Boards of Health shall be constituted, which shall consist of at least one analyst, one physician, one barrister, and one retired merchant. No member of these boards shall, while acting as such, be directly or indirectly engaged in the sale of food or drugs.

The first members of such boards shall be appointed by the House of Representatives of each State, and they shall be appointed for three years.

....dollars.

The members of this board shall be remunerated for their services at the rate of The first duty of each of these boards shall be to appoint a public analyst, or public analysts, and an inspector or inspectors, and to arrange for the payment of their remuneration. The remuneration of public analysts shall consist of an annual salary not exceeding ........ dollars, and the sum of........ dollars per sample analyzed. When a public analyst is called to give evidence in any case, he shall receive, in addition, the sum of ........ dollars per day and his travelling expenses. The public analyst shall be appointed for a term of not less than three years. The State board may, if they think desirable, provide and furnish a laboratory for him. The remuneration of the inspectors shall consist of a sum not exceeding ....dollars per annum, and the sum of........dollars per day travelling expenses when actually travelling on his business. Every inspector so appointed may appoint a deputy to act for him when desirable, at a salary of ......dollars.

Every public analyst so appointed shall be an analyst who has been in actual practice for two years, and who is skilled and has had practical experience in chemical and microscopical analysis.

Every inspector to be so appointed shall be a man of due experience and discretion, and the choice shall by preference be made from those who have already had experience in other sanitary work.

It shall be the duty of each inspector appointed under this Act, from time to time, to procure samples of every article of food or drink or drugs exposed for sale, or on sale, in any street or shop, or store, or other place, or being delivered to consumers, and to submit these samples to the public analyst for analysis. In purchasing these samples the inspectors shall, as regards the class of goods purchased and the time of purchase, act under the direction of the public analyst, subject to any control by the State boards. The number of such samples shall not, in any district or township, be less than one per annum per thousand of the population.

When an inspector has purchased any sample, he shall divide it into two portions, each of which shall be sealed with an official seal. Should the vendor request it, he shall be at liberty to affix his own seal to each parcel. The inspector shall forthwith transmit one portion of the sample by mail, express, or otherwise to the public analyst, or shall personally deliver it to the public analyst, and shall retain the other sealed portion of the sample until he receives the certificate of the analysis thereof, or in case the sample prove to be an adulterated one, until the case has been heard and decided by the Court.

It shall be competent for any purchaser of any article of food, drink, or drugs, who may suspect the same to be adulterated, to submit the same to the public analyst for analysis, upon payment of a fee of three dollars per sample, but it shall be the duty of the purchasers in such case to sign a declaration stating where and of whom the sample was purchased, and the price paid for it, and the name under which it was sold.

It shall be the duty of the analyst to analyze or examine all samples submitted to him by the inspectors or purchasers as aforesaid, and to report upon them by a certificate, on a form similar to that given in the schedule to this Act.

The said certificate shall be prima facie evidence in any Court, so that the attendance of the analyst may be dispensed with. It shall be the analyst's duty to state in this certifiate whether the article is adulterated or not adulterated, according to the meaning of this Act, and if it is so adulterated he shall state, as far as practicable, the nature and percentage of that adulteration, and whether the same would render the article injurious to health, and whether the same is so small in quantity as to render it desirable not to prosecute for a first offence, together with any other observations he may think it desirable to make.

From and after the passing of this Act no person shall, except as hereinafter provided in Section 11, sell or offer or expose for sale, or deliver any adulterated article, either in the streets or in any store or market or shop, or stall, or other place of business, or on a round from house to house, under a penalty for the first offence not exceeding 50 dollars, for the second offence a penalty not exceeding 100 dollars, and for the third and subsequent offences a penalty not exceeding 250 dollars, and in addition to the latter penalty the Court shall, in the case of a third offence, order the publication of the name and address of the vendor, and of the fact of his having been twice or more frequently previously convicted in the local or district papers at his own cost. But if the certificate of the public analyst shall state that the sample has been so adulterated as to be injurious to health, the court is hereby empowered to increase the penalty imposed to any sum not exceeding five times the amount of the maximum penalty laid down for first, second, and third offence.

The fines and other payments shall be applied towards the expenses incurred under this Act. Notwithstanding the preceding sections of this Act, it shall be lawful to sell any admixtures of substances or substitutes for substances, such as are already recognized as ordinary food products, provided that the same are not injurious to health, and that the vendor by himself or his servants makes a declaration of admixture to the purchaser at the time of, or prior to the delivery of the article, either by means of a label affixed to the sample stating distinctly that the substance is a mixture, or by a verbal declaration that the article is sold as a mixture.

The limits attached to the definitions, and forming Schedule B of this Act shall, in the first instance, be taken as the limits of strength or purity of the various articles therein enumerated, but it shall be competent for the State Board of Health from time to time to revise the figures therein contained, or to add other limits to them.

Every person selling, or offering or exposing any article of food or drugs for sale, or delivering any article to purchasers, shall be bound to serve or supply any inspector appointed under this Act who shall apply to him for that purpose, and on his tendering the value of the same, with a sample sufficient for the purpose of analysis of any article which is included in this Act, and which is in the possession of the person selling, under a penalty not exceeding 50 dollars for a first offence, and 100 dollars for a second and subsequent offences.

Each analyst shall submit a quarterly report to the State Board of Health, giving the results of all the analyses made by him during the preceding quarter, and these reports shall be published either quarterly or annually.

The analysts appointed by the various States shall from time to time meet and decide upon the most suitable and efficient processes for the various analyses to be made. These processes shall be submitted to the State Board of Health, and after receiving their sanction they shall have the force of a Schedule to this Act, until again amended by the analysts so assembled, and the amendment confirmed by the State Board.

No public analyst shall give a certificate of the adulteration of any article of food or drugs, unless he has worked according to one of these processes.

THE SECOND ESSAY, BY MR. V. M. DAVIS,

Contains no Definition of Adulteration, but the Principal Clauses of the Proposed Act

are as under:

SECTION I.—The term food and drink shall include every article used by man as food and drink, except drugs and water.

SECTION II.-The term adulterated food and drink shall include any article of food and drink to which there has been added any foreign substance or substances, whose presence is not acknowledged in