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joint letter from Dr. Jenkins and myself, expressing the opinion of this station
on the matter in question.

Very truly, yours,

JOHN PHILLIPS STREET, M. S.,
Chemist in Charge, Analytical Laboratory.

213.

Dr. H. W. WILEY,

UNIVERSITY OF TENNESSEE,
AGRICULTURAL EXPERIMENT STATION,

Knoxville, January 17, 1908.

Chief, Bureau of Chemistry, Department of Agriculture,

Washington, D. C.

DEAR SIR: I heartily agree with the contention of the Board of Food and
Drug Inspection in regard to their decision that "corn sirup" is not a proper
synonym for "glucose."

Very truly, yours,

C. A. MOOERS,
Chemist and Agronomist.

Dr. H. W. WILEY,

214.

CALIFORNIA STATE BOARD OF HEALTH,
STATE FOOD AND DRUG LABORATORY,
Berkeley, January 17, 1908.

Chief, Bureau of Chemistry, Department of Agriculture,

Washington, D. C.

DEAR SIR: Many thanks for your telegram of the 15th instant. It was a
great help to me at the meeting of the fruit growers yesterday and was the
means of correcting several false impressions concerning foreign standards.
With reference to your circular letter of the 5th instant, I will say that I
heartily agree with the findings of the Board of Food and Drug Inspection and
concur in the opinion of Mr. J. E. Gardner, attorney for the State board of
health, in which he says:

"I see nothing I can add to the opinion of the Board of Food and Drug In-
spection. The use of the term 'corn sirup' to designate and as a synonym for
'glucose' is clearly a violation of both the Federal and State laws. The com-
pany's experts have admitted themselves completely out of court."

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DEAR SIR: In reply to your letter of January 6 I beg to state, first, that the
law of Illinois recognizes "corn sirup as a term synonymous with "glucose."
Had the department been in possession of the facts presented in the "statement
of the case," things might have been different, though of that I can not be

sure.

Personally I believe that when there is a product made from the evaporated
juice of the cornstalk, containing sucrose and sold in commercial quantities as
corn sirup, that no other product is entitled to that name. I believe that any
other statement in regard to my views on the case are entirely unnecessary, as
the whole question is covered by the above statement of my views.

I regret that work on our annual report has prevented my answering your
letter at an earlier date.

Yours, very truly,

T. J. BRYAN, State Analyst.

216.

Dr. H. W. WILEY,

SUGAR EXPERIMENT STATION OF THE

LOUISIANA STATE UNIVERSITY,

Audubon Park, New Orleans, La., January 22, 1908.

Chief, Bureau of Chemistry, Department of Agriculture,

Washington, D. C.

DEAR SIR: Replying to your letter inclosing copies of the standards of the
food law, and a statement of facts relative to the Corn Products Refining Co.,

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as to the nomenclature of their product-that is, whether corn sirup" is a proper synonym for glucose "-I will state that it is not a proper synonym but is entirely misleading, and I fully concur in the rulings and statement made by the committee in this case. Corn sirup, according to our definition of sirups, should unquestionably be a sirup produced from the juice extracted from the corn or its accompaniments, and not a by-product from the treatment of corn changing its composition, character, etc. Corn sirup has been manufactured in this country by extracting the saccharine juice of the corn for a number of years and is now manufactured, to my knowledge, in western Pennsylvania, and is made from the juice extracted from the stalk of the corn. Whereas glucose, as we commonly term it, is the result of the hydrolyzation of the starch obtained from the corn, and should be termed, as it is popularly known, "glucose." I think the two wordings are distinct and should remain so. Very truly, yours, R. E. BLOUIN, M. S., Assistant Director.

H. W. WILEY,

217.

UNIVERSITY OF NEVADA, Reno, Nev., January 22, 1908.

Chief, Bureau of Chemistry, Department of Agriculture,

Washington, D. C.

SIR: In reply to your letter of January 5 on the subject of "corn sirup as a proper synonym for glucose," I beg to submit the following:

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From Circular No. 34, United States Department of Agriculture, under definition of sirup and glucose products, it appears evident that corn sirup" should be classified under glucose and not under sirup.

Further, the admission made by Dr. T. B. Wagner, of the Corn Products Refining Co., would indicate that they are conscious of deceiving the purchaser in the composition of their "sirup." The spirit of the pure-food law certainly intends that the consumer should know exactly what he buys, and buying glucose under the impression that it is sirup is not furnishing him true and accurate information.

Respectfully,

218.

J. E. STUBBS, President.

MISSISSIPPI AGRICULTURAL AND MECHANICAL COLLEGE,
DEPARTMENT OF CHEMISTRY,
Agricultural College, Miss., January 22, 1908.

Dr. HARVEY W. WILEY,

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Chief, Bureau of Chemistry, Department of Agriculture,

Washington, D. C.

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DEAR SIR: Referring to your communication of the 5th instant in regard to the decision of the Board of Food and Drug Inspection on the subject of corn sirup as a proper synonym for glucose," I beg to state that I have now had an opportunity of considering carefully the facts of the case, and in view of the wording of the food and drugs act, I hardly think that corn sirup" can be accepted as the satisfactory equivalent of “ glucose" within the meaning of the law, and certainly it is not a satisfactory synonym for a mixture of glucose and refiners' sirup. In the latter case especially it is difficult to set up the contention that the words corn sirup' are not misleading, and I do not believe, therefore, that they can be considered allowable under section 8 of the food and drugs act.

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In addition to the above, the standards of purity proclaimed by the Secretary of Agriculture (Circular No. 19) would plainly not permit the commercial article known as glucose or glucose sirup to be sold as corn sirup.

Very respectfully, yours,

219.

W. F. HAND, Ph. D.,

State Chemist.

AGRICULTURAL EXPERIMENT STATION OF THE RHODE ISLAND
COLLEGE OF AGRICULTURE AND MECHANIC ARTS,
Kingston, R. I., January 29, 1908.

CORN PRODUCTS REFINING Co.,

New York, N. Y.

GENTLEMEN: Referring to yours of the 22d instant, I will say that no one would, perhaps, attempt to question that commercial glucose made from corn

has been called corn sirup, just as lots of other sweet-tasting concoctions have been called sirup. This, however, is not the point at issue as I look upon the matter, for as you well know the expressed, evaporated saccharine juice of the cornstalk has long been known as corn sirup, and was, according to the best of testimony, so known probably long before the manufacture of glucose was attempted, hence when it comes to a question of priority glucose has not the right to the name corn sirup."

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Furthermore, to my mind, the most logical procedure when it comes to the use of definitions for regulating commercial traffic in such productions is to follow natural and logical lines, which would involve, in my opinion, the use of the term sirup most logically in connection with the sweet evaporated juices of plants. It must be evident to anyone that to have two different kinds of products called by the same name, when matters of definition in connection with official control arise, is an absurdity, even notwithstanding that two different products may have been called by the same name before such need of more exact definition arises.

The case in point reminds me of a statement I once heard made by an eminent New York judge, who said that there were times when one should use common sense in connection with rulings, rather than to hunt around through musty law books for some senseless precedent.

While you have considerable ground for arguing that you have a right to call glucose corn sirup on the strength of past usage, based upon certain grounds, yet that is an entirely different question from what should be the stand taken now that definite definitions are desirable which shall prevent the sale of two entirely different products under the same name. I am, very respectfully, yours,

220.

AGRICULTURAL EXPERIMENT STATION OF THE RHODE ISLAND
COLLEGE OF AGRICULTURE AND MECHANIC ARTS,

Dr. H. W. WILEY,

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Kingston, R. I., January 30, 1908.

Chief, Division of Chemistry, Washington, D. C.

MY DEAR DR. WILEY: Having received recently a voluminous consensus of opinions from a number of eminent chemists regarding the use of the term corn sirup" in connection with glucose, I beg to inclose to you my reply to the Corn Products Refining Co., in relation thereto, which sets forth my views in the matter, which you will note are not wholly in accord with some of the authorities. H. J. WHEELER, Ph. D., Director.

Very truly, yours,

221.

IOWA STATE COLLEGE AGRICULTURE AND THE MECHANIC ARTS,
EXPERIMENT STATION, CHEMICAL SECTION,

Ames, Iowa, February 1, 1908. MY DEAR SIR: After carefully reading "The opinions of various chemists and others on the meaning of the word sirup' and the uses of the word 'corn sirup' under the food and drugs act of 1906, presented to the Hon. James Wilson, Secretary of Agriculture, December, 1907, by the Corn Products Refining Co., of New York," I am of the opinion that the word sirup may properly be used for any thick, sweet solution of one or more sugars, and that prefixing to the word sirup such attributive words as "maple" or "cane" signifies not only the source from which such sirup is derived, but also carries with it a definite, well-known idea of flavor and quality characteristic of the source.

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The term glucose sirup" or grape-sugar sirup" gives from its attributive word " glucose" or grape sugar" a definite, well-known idea of flavor and

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quality and may properly be used to designate any sirup obtained by the action of acids on starch. The attributive word "corn," when used in connection with sirup, does not so characterize glucose that is derived from the starch of the corn grain by the action of acids, etc. This term, if applied to glucose derived from cornstarch, would imply that this sirup had some characteristics of quality and flavor appertaining specifically to corn. This obviously is not the fact, since the characteristics of glucose obtained from corn are very similar, if not idenMeal, with those of glucose derived from any other source.

In my opinion, one might with equal justification apply the term maple sirup to cane sirup, on the basis that the sugars are the same, as to apply the word corn sirup to glucose, even though that glucose were obtained from the starch of corn. This opinion is based on the fact that cane sirup and maple sirup have definite, well-known characteristics of quality and flavor that depend specifically upon their source; prefixing the word "corn" directly implies similar characteristics.

Since glucose derived from cornstarch has no such definite characteristics of quality and flavor dependent on its source, the prefixing to sirups derived from glucose the word " corn” is a deceptive use of the word, through its implication. Respectfully submitted.

Dr. H. W. WILEY,

LOUIS G. MICHAEL, Chemist.

Washington, D. C.

222.

AGRICULTURAL EXPERIMENT STATION,

RHODE ISLAND COLLEGE OF AGRICULTURE AND MECHANIC ARTS,
Kingston, R. I., February 6, 1908.

Dr. H. W. WILEY,

Chief, Bureau of Chemistry,

Department of Agriculture, Washington, D. C.

DEAR DR. WILEY: Referring to yours of the 1st instant, I will say that you are at liberty to make such use of the copy of my letter to the Corn Products Co. as you desire. My only regret is that I did not add my sentiments in relation to the value of ex parte evidence secured under the conditions probably existant in this particular instance.

Very truly, yours,

H. J. WHEELER, Ph. D., Director.

223.

Dr. H. W. WILEY,

Department of Agriculture, Washington, D. C.

DEAR DR. WILEY: In the light of evidence recently submitted, I have carefully considered the application of the term sirup to the product "Karo or Corn Sirup." I think the term "sirup" is used to designate a form of matter-a thick liquid, usually of a sweetish taste. It need not necessarily be sweet, as we have a chemical" sirupy phosphoric acid."

In my opinion, the use of the term "corn sirup" is exactly analogous to the use of the term wax. A wax is an ester of a menatomic alcohol, as beeswax. The term, however, has come to be applied to materials of a nature or texture resembling beeswax, as paraffin wax, which is a hydrocarbon, and myrtle or bayberry wax, which is, strictly speaking, a fat-an ester of a triatomic alcohol. I therefore see no occasion to change my opinion as to the applicability of the name 66 corn sirup," as expressed in my letter of December 19 to the Corn Products Refining Co. Yours, very truly,

AUGUSTUS H. GILL, 525 Boylston Street, Boston.

224.

Dr. H. W. WILEY,

Washington, D. C.

DIVISION OF CHEMISTRY,

UNITED STATES DEPARTMENT OF AGRICULTURE,
Washington, D. C.

DEAR SIR: The undersigned fully agrees with stand which the Board of Food and Drug Inspection has taken in the matter concerning "corn sirup as a proper synonym for glucose." Commercial glucose is absolutely deficient in the mineral matter, which is so necessary in all the processes of nutrition, and which is contained in maple, cane, and sorghum sirups, and should not be placed in the same category with the latter.

Very respectfully,

H. A. WEBER.

225.

Prof. H. W. WILEY,

Department of Agriculture, Washington, D. C.

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MY DEAR DR. WILEY: To me the term glucose," as applied to such a sirup as that produced by the Corn Products Refining Co. would be wholly misleading, for this term means to me the sugar C6H12O6.

On page 4, S. 8, you say that the principal constituent of "glucose" is dextrine.

To me, therefore, the designation "glucose" for the commercial product to which you propose to apply this name would be misleading. I must confess that the term corn sirup suggested to me, the first time I heard it, the real nature of this product and I never thought of a possible confusion with a sirup made from the expressed juice of the stalk. How others would interpret these terms I do not know, but it seems to me that some other designation than glucose should be applied to the commercial product, for this word already has a perfectly definite meaning in chemistry and should not receive official recognition in an entirely different sense.

The public has been misled into believing that "glucose" designates a harmfuel substance, and it is an injustice both to the public and the manufacturer to label wholesome products in such a way as to perpetuate this erroneous conception. Some designation should be found which will make the real nature of these commercial products perfectly plain and at the same time avoid the prejudice excited among the ignorant by the term glucose. Yours, sincerely,

THOMAS B. OSBORNE,

52 Trumball Street, New Haven, Conn.

226.

OKLAHOMA AGRICULTURAL AND MECHANICAL COLLEGE,

Stillwater, Okla.

DEAR SIR: I have the honor to reply to your communication of January 3, 1908, as follows: After again going over "Rules and Regulations for the Enforcement of the Food and Drugs Act" and "Standards of Purity for Food Products," I am forced to the conclusion that, by the wildest stretch of imagination, glucose can not be called a sirup, neither can this specific product (not extract) of corn be called "corn sirup."

To my mind the point raised by the Corn Products Refining Co. is not well taken. It is nothing other than a subterfuge on the part of the company to place glucose on the market under a less objectionable name, but it is "glucose all the same, and should be so labeled.

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I trust the board will not reverse itself but "stand pat." They are right and will have the support of unbiased chemists.

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The maple-sirup market was
The sirup market also seems

Hitherto glucose and mocorn sirup," and the glucose continued for a long time to

Unless all signs fail, the market for honey this fall will be higher than it has been for some time, for very good reasons. in fairly good shape, and the price is very high. to be in a bad way, but for very different reasons. lasses (or cane sirup) were blended and sold as people have flattered themselves this would be come. It is evident the Department of Agriculture at Washington regards both products as detrimental to the health of the persons who eat them. No action has yet been taken by the department to declare them so, but it is evident it is only a question of time when both will be barred.

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