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36
Trades Descriptions Act, 1968
During the year some 26 complaints alleging contraventions of the Act were received in the department.
These included matters relating to cheese, eggs, fish, bread, meat and biscuits.
This Act has now been in operation for over three years and has been seen to be a valuable contribution
to the enforcement powers of local authorities, although its provisions overlap in some respects those of
other specialised legislation, such as the food and drug laws.
The Board of Trade (now the Department of Trade and Industry) was aware that such a situation would
arise when the Act was introduced and hoped that where prosecutions were undertaken in such cases of
overlapping offences they would be taken under the appropriate specified legislation rather than the Trades
Descriptions Act.
None of the matters referred to the department during the year reached the stage of legal proceedings,
but informal action was taken under the appropriate food legislation.
Advice on Labelling of Pre-Packed Food
During the year a large number of enquiries was received by the Food Control Section requesting advice
on the labelling of pre-packed foods. These enquiries were mostly in anticipation of the new Labelling of
Food Regulations 1970, which come into effect on 1st January, 1973.
Enquiries are often received from manufacturers abroad who intend to market their products in the
United Kingdom; some have personally attended at the Health Department to discuss their proposals.
In many cases the proposals have involved an outlay of considerable expenditure in presentation alone,
and it is sometimes difficult to explain to enquirers that although specimen labels, which are often
produced without prior consultation, may provide an attractive display both pictorially and descriptively,
they fail to comply with the statutes. The requirement with which manufacturers most often find difficulty
in compliance is that relating to the declaration of the appropriate designation or common or usual name of
the food — which is intended to indicate to a prospective purchaser the true nature of the food in the pack.
The complex Regulations and ancillary legislation require special study and the Senior Public Health
Inspector of the Food Control Section has acquired a comprehensive knowledge of the legislation involved
which is invaluable to those seeking advice and guidance. There is, of course, no central agency which
provides this service and views and opinions expressed by the Health Department can only be for purposes
of guidance; any authoritative interpretation of the relevant acts and regulations governing the labelling of
pre-packed food must rest, of course, with the Court.
Non-Returnable Plastic Milk Bottles
Several enquiries were received during the year concerning the use of non-returnable milk containers.
The Health Department's food control section has followed the development of this innovation with
interest as returnable glass bottles are frequently subjected to mis-use with the result that the normal
methods of bottle washing may in some cases be ineffective, and unless "spotted" on the filling line the
bottles could be supplied to the public in a dirty condition. The situation is aggravated by the increasing
automation of bottle washing plants with filling rates of up to 400 bottles per minute on each line. This
renders sighting of individual dirty bottles almost impossible, and this is evidenced by the fact that during
the year several incidents of this nature were referred by this department to the local authority for the area
where the milk had been bottled in order that appropriate action could be taken. The Milk and Dairies
(General) Regulations require that every vessel for containing milk shall be in a state of thorough cleanliness
before use, and establish that the offence occurs at the place where the milk is bottled.
From a hygienic aspect, non-returnable plastic containers would offer definite advantages, although
questions have been raised as to the disposal problem which would result from their use. It is understood
that providing their number did not increase at such a rate as seriously to raise the percentage of plastic in
relation to other constituents of refuse, at present between 1-2 per cent, no unusual problem is likely to be
encountered in dealing with such containers.