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34
(i.) "So far as we are aware, there is no Section in the Food and
Drugs Acts 01 subsequent Regulations which make it obligatory on the part
of a manufacturer to state on the label that a preservative has been used
and the amount, and we shall esteem it a favour if you will kindly refer
us to any Section or Regulations bearing on the subject.''
(ii.) "In reply to your letter we beg to say that we have always
understood that for the small amount of salicylic acid used in our cordials
it was unnecessary to make any statement on the labels. If you will be
good enough to inform us of the state of the law on the question we shall
take care to keep within its provisions."
The general standard guiding local authorities in the institution of proceedings
is that suggested by the recommendations of the Departmental Committee in a
Report dated 1901. These recommendations have not been given effect to by
law; the standard has been found unsatisfactory moreover in connection with the
greening of preserved vegetables; although three (of four) members of the
Departmental Committee recommended that the use of copper salts should be
prohibited, one member, in a minority report, recommended that its use should
be allowed, subject to declaration and limitation to two grains of crystallised
copper sulphate per pound. This minority recommendation leads to manufacturers
assuming that a small quantity of sulphate of copper is allowed by the Sale of
Food and Drugs Acts for the purpose of keeping the colour of peas. This
assumption is wrong, but these two recommendations, neither having legal force,
increase the difficulties of local authorities administering the Sale of Food and
Drugs Acts.
It is frequently urged by traders and their legal and technical advisers that
the effect of the recommendations of the Departmental Committee is to establish
a right to use chemical preservatives, although the correlative recommendation
that its presence should in all cases be declared is not so generally accepted, and
that its presence should in all cases be declared is not so generally accepted
Local authorities are constantly called on to incur the expense of expert
evidence in support of prosecutions for preservatives in food, and appeals
from one Court to a higher and more expensive Court. Further difficulty
is experienced by reason of the conflicting views on the use of preservatives.
It will be remembered that although the Departmental Committee recommended
the limitation of boric acid in cream to 0.25 per cent., the Milk
and Cream Regulations fix the limit at 0.4 per cent. I have already
mentioned that the Departmental Committee recommended that the use of copper
salts for greening preserved vegetables should be prohibited, but one member of
the Committee favoured its use, the quantity not to exceed two grains per pound
crystallised copper sulphate. Yet there is considerable evidence that a quantity
not exceeding one grain per pound is ample for all trade purposes. And again
the Departmental Committee recommended the limitation of salicylic acid in
liquid food to one grain per pint, but a case recently taken before a Metropolitan
Police Magistrate where the amount exceeded two grains per pint, was dismissed
with costs against the Borough Council.