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those embodied in the Board's communication were conveyed in circular
letters issued by the Board on 28th December, 1901, and 27th March,
1905. Apart from the inconvenience which must occasionally be caused
owing to the time limit of 28 days imposed by the Sale of Food and
Drugs Act, 1899, it would be unfair to impose upon local authorities
the duty of conducting a preliminary judicial investigation in every
case of milk adulteration, and any suggestion having this end in view
must reflect upon the soundness of the basis upon which the Sale of
Milk Regulations rest. Moreover, each case in which legal proceedings
were eventually instituted would, under the suggested regime, be carried
to the court prejudiced, the local authority having been allotted the
double role of judge and prosecutor. The Board of Agriculture have
had their attention drawn to the Board's circular letter of 1901, in
which it was stated that "the limits below which a presumption is
raised that the milk is not genuine were necessarily fixed at figures
lower than those which are usually afforded by genuine milk," and
further that "the evidence given before the Milk Regulations Committee
tended to show that the practice of fraudulently mixing separated milk
with new milk has become increasingly prevalent," a statement which
makes the Board's suggestion still more inexplicable.
In addition to this it may be said that the present standard is below
that of milk from an average normal, healthy herd of cows. On account
of the use of milk for the feeding of infants, children and invalids,
it is most important that no milk below this standard should be allowed
to be sold for human consumption, especially as, even in milk containing
3 per cent. of milk fat as required by the regulations, the amount of fat
is insufficient for the proper nourishment of infants. The physiological
estimate of fat in cow's milk is 4.5 per cent., and the average quality of
545 samples taken in four years in one borough was 3.6 per cent., notwithstanding
that this included 43 adulterated samples. Moreover, it
has been pointed out to the Board that on account of the war the
employment of married women has very largely increased, and therefore,
the number of artificially fed children will tend largely to increase,
and, in addition, there has been an enormous increase in the number
of sick and wounded for whose dietary milk is largely used. If the
Board's suggestions are generally adopted, milk producers, especially
in view of the higher prices of food stuff for cattle, will tend to
feed their cattle even less well than formerly, and the result will be
a large number of cows producing poor milk, and an increase of
tuberculosis amongst cows. For the benefit of the uninitiated it
may be said that milk may be adulterated or injuriously affected:—