sale, as such of skimmed milk. The older act, however, omitted the expression of a fixed standard for this important food product, in this respect at least, that it did not include any statement of the least quantities of milk solids and of milk fat that would be regarded as necessary to make milk legally salable for general consumption. In this respect, the former Pennsylvania milk act differed from that of most states in the Union, and was far more difficult of enforcement.

In fixing limits of composition for milk, the Legislature has, in reality, recognized a principle not recognized in the preceding State milk acts, namely, the principle that milk sold without qualification, under the name "milk," must not only be free from adulteration by skimming or watering, but must, also, not be abnormally inferior in its composition, from causes other than direct manipulation by dairymen or milk vendors. It is true that milk produced by different cows differs very much in composition, and also that there are marked variations in the composition of milk produced by the same cow, under different conditions of feeding and management, and at different times during the period of lactation. Where, however, good management, including proper feeding, is maintained, these variations are less than where poorer methods of management prevail. There are, it is true, certain rather constant differences in the character of milk produced by cows of different breeds, or, at least, by certain strains, or classes of animals in the different breeds; and among these strains, certain families of the Holstein and other Lowland breeds of cattle quite frequently produce milk low in both solids. and fat. It is also true that animals of these breeds are heavy milkers, as a class, and that in many regions of the United States these breeds have been preferred by dairymen supplying milk for direct consumption, because of certain advantages they give them for milk production, and in spite of the inferior richness of the milk they produce.

Certain other facts, however, need to be considered, in determining public policy with respect to the standardization of this highly important human food. In the first place, the milk sold at the present day for direct consumption, is very rarely the unmixed product from a single cow, but is usually the mixed product from a herd of cows. The variations in herds' milk are, therefore, those which need, chiefly, to be considered in determining the minimum limits of composition in normal milk, and the variations in herds' milk are very much narrower than those observed in the case of milk from single cows. It is true that some act of mismanagement of the herd, may affect all the animals in it at the same time, but the consequences of such mismanagement show themselves much more in the alteration of the yield of milk, than they do in its composition. Again, in herds maintained for the purpose of supplying milk for direct consumption, the cows do not usually become fresh at the same time, but, rather, are so managed in this particular that the milk supply shall be maintained as uniform as possible throughout the year. Consequently, those differences in composition appearing in the milk of a single cow, as its period of lactation progresses, are, by no means, so marked in the case of milk from dairy herds kept for the purpose just mentioned. It must, however, be frankly ad

mitted, that there are herds of Lowland breeds which, with no lack of good management, produce milk that will not uniformly, nor even in the average case, come up to the requirements of the standards commonly fixed for market milk. The owner of such a herd is, however, not driven to the dire necessity of destroying the herd; all he has to do is to introduce the necessary proportion of animals, the quality of whose milk is such as to bring the mixed herd's milk up to the normal limit; and to accomplish this change, it is not necessary for him even to reject the breed he prefers, because there have been developed in large numbers, strains of the same breed that are producing milk considerably above the minimum limits in composi tion, commonly adopted.

It is, possibly, deserving of mention in this connection, that there is one cause of variation in milk quality whereby the solids-not-fat of milk are abnormally reduced in quantity, over which the dairyman has no control, and against which he cannot guard, where the method of pasturage enters largely into his system of management. It is generally known, that in prolonged dry seasons, where the pasture becomes very short and scanty, the tendency is for the solids-not-fats to fall from one-fourth to one-half per cent. below the quantity normal to the animal, and sometimes the diminution of these constituents is even greater. It may be urged that the dairyman can, by the introduction of food from other sources, keep up both the milk flow and the milk composition; but it is fair to recognize that farm management is necessarily complex, and that the control of the food supply, in the manner just indicated, is one involved with great difficulty, and not always practicable. On the other hand, the conditions of prolonged drought, sufficient to produce the effects just described, are quite rare, and the conditions of milk production during these rare periods could be accepted as the general basis of limitation of milk composition, only at a disadvantage to the consumer that must extend through periods of time manifold longer than those during which these abnormal climatic conditions prevail. It seems, therefore, to be a wiser policy to trust to the judg ment of experts examining the milk supply, and of executive officers. charged with the enforcement of the law, to recognize the presence of these conditions, to modify their recommendations, and to avoid the carrying of the law beyond its true intent, rather than to inflict upon the consuming public a continuous disadvantage, because of the rare occurrence of such climatic conditions.

The standards of composition for milk, incorporated in the present act, are those proclaimed by the Secretary of Agriculture, under authority of Congress, and upon the recommendation of a board of experts who carefully studied the limits established by law in the several states and municipalities of the Union, and also the composition of market milk throughout the United States. From our knowledge of milk produced in Pennsylvania, a knowledge secured by the milk examinations made by this Bureau through past years, together with those made by other public agencies, it is established that the limits adopted are safely applicable to Pennsylvania market milk.

The new act differs from the act of 1909, also, in fixing 18 per cent. of milk fat as the minimum limit for cream, whereas the earlier act set 15 per cent. as the minimum limit. This change brings the State

standard into conformity with that recognized by the national authorities, in dealing with cream that enters into interstate commerce between Pennsylvania and the neighboring states. The analyses of market creams made by the chemists of this Bureau, in course of enforcement of the act of 1909, indicated that an 18 per cent. minimum for cream would not be unjust in its application to the cream trade of Pennsylvania.

PUBLICITY POLICY

The foregoing discussion of the new food acts of 1911, illustrates the fact that the pure food laws of this State, as well as other states, are, from time to time, undergoing modification in matters of detail and, in rarer cases, by the recognition of more advanced principles of public policy. It is nevertheless true, that the main principles expressed in the general food law lie at the basis, also, of these new laws, and are not set aside with the modifications of detailed legislation.

It is an assumption of the courts, long recognized as necessary to the enforcement of laws, that every citizen know the law. It is not my purpose to discuss, in this connection, the extent to which the facts support this thory. It is mentioned only as introductory to the statement, that it is the policy of this Bureau to make every endeavor to secure a general knowledge on the part of the selling public, as well as on the part of the consumer, relative to the provisions of the food laws and of regulations issued thereunder, in order that the practices of the manufacturer and dealer may be, so far as practicable, brought into compliance with the law without resort to the method of legal prosecutions.

The agencies employed for the spread of information concerning new acts and regulations have been various. The work has, in part, been accomplished by the efficient services of the agents of the Bureau, in the course of the exercise of their regular duties as purchasers of samples; in part by articles of information prepared by this office, and distributed throughout the State by the courteous assistance of the public press; and in part by addresses made by the Commissioner, or his representatives, to various trade organizations concerned.

In pursuance of the policy here outlined, manufacturers of sausage and dealers in milk were promptly informed of the new legislative acts affecting their business, with the result, it is believed, that very few of those engaged in these lines of production failed to have knowledge of the recently adopted legal requirements, before the work of the Bureau in the enforcement of these laws by the examination of samples and the institution of prosecutions, was begun.

In like manner, widespread notice was given when it became evident that it was the duty of the Food Commissioner to bring before the courts, for judicial determination as to its legality, the practice by confectioners of coating certain classes of their wares with resinous glazes, such as shellac or the grass gums. One further illustration of the same policy may be mentioned at this time. Earlier experience had shown that stocks of breakfast foods and other cereals, held through the summer months, often became the subjects of insect attack during the warm period, and were thereby rendered unfit for

use as human food. When it was determined, for this reason, that instructions should be given to sampling agents to give especial attention during the early fall to commodities of this class, a corresponding notice was issued through the press, urging that retailers examine their own stocks at once, and remove therefrom any packages that had been attacked and rendered unfit for use, to the end that the consumers might thereby have the needed protection, without recourse to prosecutions, so far as such warning might serve this purpose.

Speaking generally, it is the policy of the Bureau to use, so far as practicable, publicity measures of the kind above described as the first means of enforcing the law, with the hope that they will prove sufficient, in case of most dealers, so that the more severe measure of resort to court procedure may be kept down so far as the safety of the public may permit.

THE MONTHLY BULLETIN

The Monthly Bulletin of the Bureau has served during the past year, as during the preceding years, as the means of giving to the public current information concerning the work of the Bureau, and the policy originally adopted by which it was made a medium not only of statements concerning the statistical work of the Bureau, but also of general information on the subject of food production and food control, has been continued.

The demand for these Bulletins and the general interest with which the public has received them, have continued in such degree as to prove their value for the purpose stated.

SUMMARY OF WORK FOR THE YEAR 1911

In the Appendix to this report are presented summaries showing the list of articles purchased by the agents and analyzed by the chemists of the Bureau during the year, and also a table giving a list of those classes of articles found adulterated and misbranded, and made the basis of prosecutions that have been terminated during the year. The recapitulation of samples analyzed during 1911 shows a total of 8,200, a number far in excess of the report for any single preceding year during the existence of the Bureau. The number of cases terminated also exceeds the previous record, the number being 1,029. The increase in these numbers is due, very largely, to the greater number of samples of dairy products examined since the passage of the new milk act of June 8, 1911, the total number of these samples analyzed since that enactment being 4.957, as compared with 3,296 samples of these products analyzed in 1909.

In the following portion of this report the several classes of food products analyzed will be considered separately in detail:

DAIRY PRODUCTS

The number of milk samples examined during 1911 was 3,512, a portion of the work falling under the act of 1909, but the larger part under the act of 1911. As the result of these analyses, there were

prosecuted and terminated for violation of the act of 1911, 418 cases. That is to say, the chemists' findings showed, on the average, out of nine samples examined one illegal in quality. The general character of the analytical results indicates that adulteration by the addition of water was of as frequent occurrence as that by the Temoval of milk fat. It ought further to be mentioned that a very considerable fraction of the cases instituted were based upon the analyses of milk sold at hotels and restaurants, which were visited somewhat more generally than usual. It is clear from these findings that the public greatly needed the protection which this new milk act affords.

There were terminated during the year 7 cases brought for the reason that formaldehyde had been added to milk, no instance appearing in which boric acid had been so used. The number of cases found this year, as compared with the 5 reported for 1910, is not out of proportion to the latter number when the difference in the number of samples in the two years is taken into account. The condition of the milk supply as respects its freedom from chemical preservatives, remains highly favorable, especially when the widespread use of these objectionable preservatives in the milk supply on the markets a few years ago is recalled. There were also terminated during this year, 38 cases brought for milk adulteration, under the act of 1909, and two brought under the food act of 1907.

CREAM

During 1911, 1,038 samples of cream were analyzed, and during the year there were 150 prosecutions terminated for the sale of cream . containing less than the standard quantity of butter fat. Supplementary sampling of the cream stocks of a number of communities showed a very wholesome improvement in the quality of the cream supplied, following the first series of prosecutions brought for violations of the law.

When it is recalled that within a very few years customers asking for cream were frequently supplied with a product containing but 6 to 8 per cent. of butter fat, although the cream secured by the oldfashioned method of skimming commonly contained over 30 per cent. of fat, it will be realized how much better assurance the householder can have, under the present act, of getting a fairly uniform, good

cream.

CONDENSED MILK

Duing 1911 there were examined 11 samples of products sold as condensed milk and evaporated milk, but the present year has witnessed the termination of no case instituted for the violation of the laws, as they apply to these materials.

SKIMMED MILK AND BUTTERMILK

There were examined during the past year 116 samples of skimmed milk and 3 samples of buttermilk, the sale of which, under these specific names, is allowed by the present laws. Three cases of additions of water to skimmed milk were terminated during the year, showing that, as respects adulterations by such additions, the skimmed milk supply is not in a serious condition.