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Proposed Sanitary Inspection Law for States.

Prepared by Committee on State Sanitary Inspection Law, appointed at the Twelfth Annual Convention of the Association of State and National Food and Dairy Departments.

Food authorities who have had to do with work of inspection, who have become familiar with some of the sanitary conditions existing in shope and factory, where little or no care is exercised in sanitary matters, have long felt the necessity for a proper law which would regulate the sanitary conditions in such places.

The Association of State and National Food and Dairy Departments at their annual convention at Jamestown, Va., in 1907 adopted the following resolution:

"Resolved. That sanitary inspection should be extended to include small slaughter houses, small poultry and killing houses, creameries, cheese factories, dairy farms, milk depots, ice cream factories, restaurants, hotels, groceries and meat markets and all other places where food is produced, manufactured, stored or offered for sale, and that such inspection should include the sanitary condition of the buildings and utensils, herds, workmen and their clothing, and the condition of the raw material and the finished product."

The President of the Association of State and National Food and Dairy Departments in his annual address at the Mackinac meeting, recommended that a committee be appointed to draft a bill in accordance with the resolutions above named. The association directed that such a committee be appointed and that they be instructed to prepare a bill for a sanitary measure in accordance with these provisions. The committee named were as follows:

H. E. Barnard, Indiana, Chairman.

E. H. S. Bailey, Kansas.

T. J. Bryan, Illinois.

Geo. M. Flanders, New York.

L. Davies, Washington.

J. H. Worst, North Dakota.

Chas. D. Howard, New Hampshire.

The committee formulated a bill to be modified and adapted to the conditions in the several states. In some states it will be necessary to change the wording to correspond with the title of the officer or department who has the enforcement of the law, but it is believed that the law should be enforced by the same department as has the enforcement of the Food and Drug Act of the state.

Two titles for the bill are presented, A and B, a short and a long title, to meet the requirements under the constitutional provisions of the various states. The bill as prepared by the committee is as follows:

TITLE 'A."

A bill for an act to promote the sanitary production and distribution of food and defining the duties of (State and local Board of Health) (State Food Commissioner) in relation thereto.

TITLE "B."

A bill for an act providing for the sanitation of bakeries, canneries, packing houses, slaughter houses, dairies, creameries, cheese factories, confectioneries, restaurants, hotels, groceries, meat markets, and all other food producing establishments, manufactories or other places where food is prepared, manufactured, packed, stored, sold or distributed, and vehicles in which food is placed for transportation, regulating the health of operatives, employes, clerks, drivers and all other persons working on the premises who handle the material from which food is prepared or the finished product; defining food; regulating the wholesomeness of food manufactured, prepared, packed, stored, sold, distributed or transported, and defining the duties of (State and Local Boards of Health) (State Food Commissioner), and providing penalties for the violation thereof.

Section 1. Be it enacted by the General Assembly (Legislature) of the State of

that every building, room, basement or cellar occupied or used as a bakery, confectionery, cannery, packing house, slaughter house, dairy, creamery, cheese factory, restaurant, hotel, grocery, meat market or other place or apartment used for the preparation for sale, manufacture, packing, storage, sale or distribution of any food, shall be properly lighted, drained, plumbed and ventilated and conducted with strict regard to the influence of such condition upon the health of the operatives, employes, clerks or other persons therein employed and the purity and wholesomeness of the food therein pro

dued and for the purpose of this act the term "Food" as used herein, shall include all articles used for food, drink, confectionery or condiment whether simple, mixed or compound and all substances or ingredients used in the preparation thereof.

Sec. 2. The floors, side walls, ceilings, furniture, receptacles, implements and machinery of every establishment or place where food is manufactured, packed, stored, sold or distributed, and all cars, trucks and vehicles used in the transportation of food products, shall at no time be kept in an unclean, unhealthy and unsanitary condition, and for the purpose of this act, unclean, unhealthful and unsanitary conditions shall be deemed to exist if food in the process of manufacture, preparation, packing, storing, sale, distribution or transportation is not securely protected from flies, dust, dirt and, as far as may be necessary by all reasonable means, from all other foreign or injurious contamination; and if the refuse, dirt and the waste products subject to decomposition and fermentation incident to the manufacture, preparation, packing, storing, selling, distributing and transporting of food, are not removed daily; and if all trucks, trays, boxes, baskets, buckets and other receptacles, chutes, platforms, racks, tables, shelves and all knives, saws, cleavers and other utensils and machinery used in moving, handling, cutting, chopping, mixing, canning and all other processes are not thoroughly cleaned daily, and if the clothing of operatives, employes, clerks or other persons therein employed is unclean.

Sec. 3. The side walls and ceilings of every bakery, confectionery, creamery, cheese factory, hotel and restaurant kitchen, shall be well plastered, wainscoted or ceiled with metal or lumber and shall be oil painted or kept well lime washed, and all interior wood work in every bakery, confectionery, creamery, cheese factory, hotel and restaurant kitchen, shall be kept well oiled or painted with oil paints and be kept washed clean with soap and water; and every building, room, basement or cellar occupied or used for the preparation, manufacture, packing, storage, sale or distribution of food. shall have an impermeable floor made of cement or tile laid in cement, brick, wood or other suitable monabsorbent material which can be flushed and washed clean with water. Sec. 4. The doors, windows and other openings of every food producing or distributing establishment during the fly season shall be fitted with self closing screen doors and wire window screens of not coarser than 14 mesh wire gauze.

Sec. 5. Every building, room, basement or cellar occupied or used for the preparation, manufacture, packing, canning, sale or distribution of food, shall have convenient toilet or toilet rooms separate and apart from the room or rooms where the process of production, manufacture, packing, canning, selling or distributing is conducted. The floors of such toilet rooms shall be of cement, tile, wood, brick or other nonabsorbent material and shall be washed and scoured daily. Such toilet or toilets shall be furnished with separate ventilating flues or pipes, discharging into soil pipes, or on outside of the building in which they are situated. Lavoratories and washrooms shall be adjacent to toilet rooms and shall be supplied with soap, running water and towels, and shall be maintained in a sanitary condition. Operatives, employes, clerks, and all other persons who handle the material from which food is prepared, or the finished product, before beginning work or after visiting toilet or toilets, shall wash their hands and arms thoroughly in clean water.

Sec. 6. Cuspidores for the use of operatives, employes, clerks or other persons shall be provided whenever necessary, and each cuspidore shall be thoroughly emptied and washed out daily with disinfectant solution and five ounces of such a solution shall be left in each cuspidor while it is in use. No operative, employe, or other person shall expectorate on the floor or sidewalls of any building, room, basement, or cellar where the production, manufacture, packing, storing, preparation, or sale of any food is conducted.

Sec. 7. No person or persons shall be allowed to live or sleep in any room of a bakeshop, kitchen, dining room, confectionery, creamery, cheese factory, or place where food is prepared, served or sold.

Sec. 8. No employer shall require, permit or suffer any

person to work, nor shall any person work, in a building, room, basement, cellar or vehicle occupied or used for the production, preparation, manufacture, packing, storage, sale, distribution and transportation of food who is affected with any venereal disease, smallpox, diphtheria, scarlet fever, yellow fever, tuberculosis, or consumption, bubonic plague, Asiatic cholera, leprosy, trachoma, typhoid fever (epidemic), epidemic dysenttry, measles, mumps, German measles, (Rothein), whooping cough, chicken pox or any other infectious or contagious disease.

Sec. 9. The Chief Inspector or Deputy Inspector or agent of the State Food Commissioner, State Board of Health, shall have full power at all times to enter and inspect every building, room, basement, or cellar occupied or used for the production for sale, manufacture for sale, storage, sale, distribution or transportation of food and all utensils, fixtures, furniture and machinery used as aforesaid, and if upon inspection any food producing or distributing establishment, conveyance, employer, operative, employe, clerk, driver or other person is found to be violating any of the provisions of this act, or if the production, preparation, manufacture, packing, storing, sale, distribution or transportation of food is being conducted in a manner detrimental to the health of the employes and operatives and the character or quality of the food therein being produced, manufactured, packed, stored, sold, distributed or conveyed, the officer or inspector making the examination or inspection shall furnish evidence of said violation to the (District Prosecutor, Prosecuting Attorney) who shall prosecute all persons violating any of the provisions

of this act, or shall report such conditions and violations to the State Food Commissioner (State Health Officer), who shall issue an order to the person or persons in authority at the aforesaid establishment to abate the condition or violation or make such improvements as may be necessary to abate them, within the period of five days or such reasonable time as may be required in which to abate them. Such order shall be in writing and the person receiving the order shall have the power of appeal from the order and instructions, and may within five days from the issuance of the order appear in person or by attorney before the State Food Commissioner (State Health Officer) to give reason why such order or instruction should not be obeyed.

Sec. 10. Any person who violates any of the provisions of this act or who refuses to comply with any lawful orders or requirements of the State Food Commissioner (State Health Officer) duly made in writing as provided in Section 9 of this act, shall be guilty of a misdemeanor and on conviction shall be punished for the first offense by a fine of not less than $10.00 nor more than $50.00; for the second offense by a fine of not less than $50.00 nor more than $100.00 and for the third and subsequent offense by a fine of $200.00 and imprisonment in the County Jail for not less than 30 nor more than 90 days and each day after the expiration of the time limit for abating unsanitary conditions and completing improvements to abate such conditions as ordered by the State Food Commissioner (Health Officer) shall constitute a distinct and separate offense.

Hearing at Atlanta, Ga., December 1-2, 1908

FOOD

BEFORE THE CONVENTION OF

CONTROL

OFFICIALS

of Virginia, North Carolina, South Carolina, Georgia, Alabama, Mississippi, Louisiana, Tennessee, and Arkansas, on Sulphur Dioxide in Syrups and Molasses

And the Resolutions there Adopted, Together with a letter to the President of the United States from the Presidents of the Louisiana Sugar Planters' Association, the Louisiana Sugar Exchange, and the National Molasses Refiners' Association.

The meeting was held at the capitol building, Mr. B. J. Purcell, deputy commissioner of Virginia, presiding, and there were present:

Mr. C. D. Harris, chemist, of North Carolina.
Mr. B. B. Ross, chemist, of Alabama.

Mr. W. F. Hand, chemist, of Mississippi.

Mr. L. T. Brown, pure food and drug inspector, Tennessee.
Dr. H. P. Jones, analyst, Louisiana state board of health.
Dr. D. Harvey Dillon, president Louisiana state board of
health.

Prof. J. T. Halsey, M. D., of Tulane University.
Wm. Stoddard, chemist, of Arkansas.

R. E. Stallings, chief board of agriculture, Georgia, acting secretary.

F. L. Parker, Jr., chemist, board of health, South Carolina. Dr. Dillon stated that Louisiana desired to be heard on the question of sulphites in syrup and molasses, and called on Prof. Halsey, Tulane University, who spoke as follows:

In order that what the speaker has to say may carry with it any weight or conviction, it is essential that he acquaint his audience with his qualifications for having an opinion on this subject. This makes it necessary for him to be somewhat egotistical at the start in stating that for the past four years he has occupied and still occupies the chair of materia medica and therapeutics at the Tulane University of Louisiana, that he prepared himself for this position by fourteen years of study and experiment, nine of which were spent in the exclusive study of physiology, especially in its chemical, pharmacological and metabolic aspects, and that he, therefore, feels that he is in a position to judge with intelligence the conclusions drawn by Dr. Wiley in regard to the effects of sulphurous acid and the sulphites as published in Bulletin No. 84, part 3. This bulletin has been studied diligently by the reader, page by page, and he believes that nothing of importance in it has escaped his notice. As a result of this careful study and analysis of Dr. Wiley's own experimental data he concludes that it is his emphatic opinion that the results obtained by Dr. Wiley and his assistants do not justify the conclusions drawn by Dr. Wiley and published in the above mentioned bulletin.

The reason for this conclusion of the speaker is as follows: 1st. The administration of the sulphite to subjects one to

six in capsules was a grave error in technique, sufficient in itself to rob the experiment of any demonstrative value. Any salts coming in contact with the mucous membranes of the alimentary canal will, if in concentrated solution, cause more or less irritation, and this is just what is almost certain to occur whenever salts are administered in such amounts and in capsules as was the case with these subjects. Dr. Wiley does not state in what concentration the sulphurous acid was administered to subjects seven to twelve and this makes it impossible to state whether the concentration was so great as to lead to an inevitable irritation of the mucous membrane. Results obtained in this fashion cannot correctly be held to show that sulphurous acid or sulphites in low concentration would produce similar results.

2d. There was no provision in the experiments to avoid psychic effects due to suggestion or auto-suggestions, as the poison squad were all aware of when they were taking the supposed poison and when they were not. Many of the symptoms noted and to which Dr. Wiley attributes significance were of the sort which every physician of experience knows may well be and frequently are the result of psychic influence.

3d. The amount of preservative administered was much larger than would be at all likely to be ingested by any possible consumption of molasses.

4th. A careful study of the data given in the bulletin leads the speaker to exclude as improper subjects for such experimentation all but five of the twelve subjects used by Dr. Wiley.

5th. Subjects 1, 2, 9, 10 and 11, which are left after this exclusion, all gained weight during the periods in which the preservative was administered. The nitrogen balance with these subjects was a positive one during the preservative period. These two facts both indicate strongly that the preservative was doing no harm, and especially that it was not affecting the general processes of metabolism unfavorably.

6th. Dr. Wiley claims that the figures obtained by analysis of the feces during the three periods speak in favor of the preservative having affected absorption unfavorably. His average figures are for dry material 110 grams in the fore period, 118 in the preservative period and 119 in the after period, figures which are insignificant in their differences and which might well have been obtained in any metabolism ex

periments where no injurious substance had been fed, for it is a matter of common knowledge that in metabolism experiments absorption in the early stages of the experiment is often much better than in the later stages, and it is to be noted that the figure for the after period is identical with the figure for the preservative period.

7th. Dr. Wiley draws the inference that the increase in the amount of urine excreted in the preservative period is indicative of a harmful action. He appears not to be aware of two essential facts in this connection-viz.: that the sulphites, if absorbed as sulphites, must immediately be transformed in the blood to sulphates, and that sulphates are diuretics and, under normal conditions at least, harmless ones.

8th. The results obtained by examinations of the blood show certain minimal deterioration of the blood condition, according to Dr. Wiley, but these differences are so slight that any one acquainted with the limits of exactness in the methods used for the determinations and the normal variations from hour to hour in the blood composition would consider such conclusions as are drawn by Dr. Wiley to be in the highest degree questionable.

9th. The figures as regards fat absorption and the calories balance are again interpreted by Dr. Wiley as indicating deleterious action of the preservative. In reality, however, the differences are so slight as to negative this conclusion.

Summarizing this matter, the speaker expresses his conviction that the experiments in Bulletin 84, part 3, do not justify the conclusion that the sulphites present in any syrup or molasses used as food are present in large enough quantities to have any deleterious effects on any consumer of this article. In his opinion these experiments justify only the conclusion that these large amounts of sulphites and sulphurous acid ingested in the abnormal manner and unfavorable conditions of the experiment, would appear to have caused a limited amount of abdominal discomfort, such as would be almost an inevitable result of administering non-poisonous salts or acids, under like conditions.

Dr. Hamilton P. Jones, Louisiana state analyst, read the following:

I should like to discuss for a few moments Bulletin No. 84, part 3, bureau of chemistry, U. S. Department of Agriculture, entitled “Influence of Food Preservatives and Artificial Colors on Digestion and Health," dealing particularly with sulphurous acids and sulphites.

A careful study of this bulletin, upon which Dr. Wiley bases his prohibition of the use of sulphurous acids and sulphites, convinces me that the evidence put forward does not warrant the conclusions reached, viz.: That their use disturbs the digestion and causes to produce albuminuria and casts.

In the first place, the form of administration of the substances experimented with was an unnatural one, and the quantities given were far in excess of any that would ever be taken in the natural course of food taking. It is not improbable that the liberation within a circumscribed area of the stomach of sodium sulphite from a capsule would cause local irritant effects, producing inflammation and secondary evidences of indigestion. It would be just as improper to study the effects of baking powder on the human system by administering it in capsules or in solution after each meal.

A good many of the men selected for the purposes of these experiments should not have been used, inasmuch as some of them had already been submitted to another series of experiments, from which they had not had time to recover. Some of them seemed to have suffered from conditions which must have existed prior to the time of experiment, these conditions being ascribed to the evil effects of the drug, notably No. 3, and, judging by the description published in the bulletin, No. 3 probably suffered from an ordinary attack of megrain or hemicrania, sometimes known as sick headache. If this be correct, this man must have had attacks of this sort at previous times.

In so far as the nitrogen, phosphoric acid and sulphur balances are concerned, the differences were so slight in the various periods as to be well within the possible margin of error and should be discarded in a consideration of this sort. Especially is this true in reference to the phosphoric acid balance, where so many factors have to be considered and guarded against in properly conducted metabolism experiments; for instance, the amount of calcium present in the food, the alkalinity or acidity of the gastro-intestinal juices, the amount of water taken and also the amount of bodily and mental activity. Where indigestion was claimed to have been produced during these experiments no analysis of gastric contents or vomit was submitted, so the real condition of the gastro-intestinal secretions is not known.

The appearance of casts in the urine have no special bearing upon the case in hand, for the reason that it is well known that casts are often thrown off with or without albuminuria as a result of physical exercise, without there being any organic disease whatsoever or any irritating subtance taken. In so far as albuminuria is concerned, the cases were not carefully enough studied prior to the experiment, and its presence was so variable during the period of experimentation as, not to justify any conclusion based upon its presence. Dr. Wiley himself says in this bulletin: "These limited data are not sufficiently decisive to establish any general effect as produced by the preservatives, and further studies were made of this point in the special series, as before mentioned, where the same contradictory evidence is furnished by the data obtained for five men, which precludes the drawing of any conclusion in regard to the production of albumin in the urine by this preservative."

The blood pressure of the various individuals experimented upon was not determined. While determining the blood pressure may not be essential to the satisfactory conduct of such experiments, at the same time a man with a high blood pressure would be subject from time to time to an albuminuria transient in character, and not dependent upon either sulphurous acid or sulphites.

The whole work is of too superficial and light a character to base any of the conclusions on that were offered regarding the harmful effects of sulphurous acid and sulphites, and the experiment should be repeated in a more careful manner and more thoroughly.

The most careful experiments carried on by the agricultural experiment station of the Louisiana State University and A. & M. College, Baton Rouge, with the co-operation of the Louisiana state board of health, on the effect on the human system of Louisiana manufactured svrups and molasses, by R. E. Blouin, P. E. Archinard and J. A. Hall, Jr., developed a series of results completely at variance with the findings of Dr. Wiley, where the subjects experimented upon uniformly improved in health, digestion, mental and bodily vigor. The hemaglobin content and blood counts in both these series of experiments show absolutely no harmful or deleterious effect on the blood by either sulphurous acid or sulphites.

As you well know, there is no authenticated instance of any one ever having been made sick by Louisiana molasses, which it has been the custom to clarify by the use of sulphur almost since the beginning of this industry in the United States. Dealers in molasses who sample it constantly, members of the Sugar Exchange, who are constantly tasting it, are men of splendid physique and fine digestion; in fact, it would be hard to find a healthier set of men than these.

Sulphites have been used in medicine to a great extent, particularly as preventives in the spread of contagious and infectious diseases, and I take pleasure in reading the following communication from Prof. Elliott, for a number of years professor of theory and practice of medicine at Tulane University:

Highland, N. C., Nov. 20, 1908. Dr. Hamilton P. Jones, Analyst, Louisiana State Board of Health:

Dear Hamilton: In reply to your letter of the 16th I would say that I regret that I am separated from all data that I have upon the sulphites and their action. There is an article in the New Orleans Medical and Surgical Journal of date January, 1880, by me, after a full medical test of sulphites as a preventive in an epidemic. I had other unpublished data of four experiments with the sulphite of soda upon the healthy individual. I have lost these, so that I can only give you an opinion.

As a preventive against scarlet fever I gave my own children, four in number, seven and one-half grains sodium sulphite, three times a day for about three months. These children varied in age from seven years to infancy; the salt was in simple aqueous solution. These children remained in perfect health, and I thought them in better health at the end of the experiment than at the beginning. The same result was obtained on about a hundred other boys and children on whom I tried the sulphites. I could detect no harmful effects upon the excretions. I have always since these experiments regarded sodium sulphite as not only without danger to the organ, but as certain to improve the general health. A very long course of careful experiment upon perfectly healthy patients should be tried before sulphur should be condemned as hurtful.

Sincerely yours,

+

* * *

JOHN B. ELLIOTT. Sulphur is a normal constituent of all vegetables.from 'which

sugar, syrups and molasses are derived, and I have been reliably informed, by representatives of the national bureau of chemistry, that sugar cane syrups manufactured without the use of sulphurous acid or sulphites in any part of the process will show on analysis for sulphites from 40 to 60 mgms. of SO2 per kilo. So that according to our present knowledge on analysis SO is a normal constituent of all syrups and molasses. There is no process at present known that enables us to differentiate between the organic and added sulphur content of the syrup. Sulphur is used in the process of manufacture of sugar, syrups and molasses solely as a clarifying agent for the purging out of objectionable resins, gums and coloring matter from the juices, and never as a preservative, and it is not proper to place it in the same category with other chemical preservatives.

The commercial aspect of this subject is of extreme importance to Louisiana and some of the other southern states, for the reason that unless sulphur is used in the clarification of sugar house juices, it is impossible for the planters to manufacture an article of sugar that would be acceptable to the consumer. The result would be if he were deprived of the privilege of using sulphur that he would be compelled to sell all of his output to refineries where bone black is used, and probably at trust prices. In other words, there would be no more of the ordinary "grocery" grades of sugar on the market.

Dr. Wiley's experiments at Evergreen plantation in 1907 were conducted by that gentleman and his assistants with a view of obtaining a product of sugar, syrup and molasses which would be of the highest commercial value to the planter.

These experiments were made, first, without any clarifying agent; second, with lime as a clarifying agent; third, with lime and sulphur dioxide; fourth, with lime and phosphoric acid.

Dr. Wiley assured the representatives of the New Orleans Sugar Exchange, both in person and by letter, that these products when made would be submitted to the exchange and offered for sale in the regular course of procedure. With these promises the doctor failed to comply. These products were shipped to New Orleans from Evergreen plantation under seal, were received at the docks by one of the department agents, who positively refused the representatives of the Sugar Exchange any sample, and he reshipped them to Washington, where they were subsequently sold to parties in the department.

With the promise of Dr. Wiley in writing, Mr. D. D. Colcock was able to secure from Secretary Wilson an order on the department to deliver samples of the sugar and molasses for the appraisement by the Sugar Exchange, said samples being appraised as follows:

The Louisiana Sugar and Rice Exchange,
New Orleans, La., Jan. 22, 1908.

We, the undersigned committee appointed to represent the Sugar Planters' Association, Louisiana Sugar Exchange and National Molasses Refiners' Association, beg to report that we have examined three samples of sugar marked:

No. 1.

(Sulphur.)

No. 2. (Half sulphur.) No. 3.

(No sulphur.)

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Dr. Dillon then called on Mr. Shilstone, who read the following:

THE NECESSITY FOR THE USE OF SULPHUR IN THE SUGAR INDUSTRY OF THE SOUTH.

Herbert M. Shilstone, Chemist for Penick & Ford, Ltd. Atlanta, Ga., Nov. 30, 1908. Under the above heading the use of sulphur in sugar making was taken up by me in a rather broad sense in an article published by the Journal of Commerce on April 3. I will attempt to treat the matter in a more scientific manner for your consideration.

The primary question to be asked and investigated is why sulphur or the fumes of burning sulphur are used and have been used by the sugar industry since 1810.

Such chemicals as lime, sulphur and phosphoric acid, which are used in the sugar industry for the purpose of removing or destroying certain coloring matter, which, if left unchanged during the process of manufacture from cane juice to sugar and molasses, would cause the production of a product of an inferior color and flavor and be not fit for consumption. These chemicals are never used for preserving or bleaching purposes, but the combination of sulphur and lime as at present used in Louisiana has been shown by exhaustive experiments to be the only method known of removing the major portion of the impurities which exist in the Louisiana sugar cane, and which are not removed by these agents individually, and are only removed when the same are combined in the proper manner for the purpose of clarification.

The question may be asked, and would better be answered here, why do we need to use sulphur in this country, when for years a high class of product is produced in the tropics, where sulphur is only a recent addition? We find in the south the actual growth of the cane plant covers a period of barely nine months, when the actual maturity of the cane to its point of production of seed at which period deterioration commences, is twelve months under the most favorable conditions, and at present in those of the West India islands where the soil has been producing crop after crop for over a hundred years with very little if any assistance from the addition of fertilizer, the cane is allowed to grow for eighteen months. We can readily appreciate that nine months' growth only permits of a partial maturity of the saccharine matter, leaving a large percentage of albumenoids and other bodies which have to be gotten rid of. These bodies, if not eliminated, not only prevent the sugar which is in the juice from properly crystallizing, but, owing to their ready decomposition, by heat, darken very rapidly in the process of operation, and so destroy the natural color of the product.

The use of sulphur dioxide in the process of manufacture is not used as a preservative, but as a collaborator with the milk of lime in precipitating as sulphites these impurities. We do know that on heating a solution of albumenoids the major portion of them are precipitated, but in the rapid process of manufacture which has to be conducted in a sugar refinery, where millions of gallons of juice are handled a day, it would be impossible to wait for a precipitate of such a light specific to settle. We therefore have to resort to some other means of eliminating this precipitate.

When sulphur is burned in air sulphurous acid gas is formed. The use of sulphurous acid in sugar work was first recommended in 1810 by Proust. The method of the manipulation of this acid has been carried through various changes. Being an acid, if improperly used, it is capable of creating great losses in the yield of crystallizable sugar, besides hindering the process of manufacture. It is of interest to note, referring to an old manual published in 1868 by Roret, and comparing it with the present methods which have been tried for introducing sulphur dioxide into the juice, that the direction for its use at the date is exactly as the method of today.

Something over forty years ago the clarification of cane juice with the assistance of sulphurous acid became a recognized method. After the first successful experiments in France it was believed that sulphurous acid was a universal panacea, decolorizing, purifying and sterilizing to the point of dethroning bone black, which up to that time had been used for the purpose. In reality it does all of these, provided that it be utilized at the proper moment and under the proper conditions.

Is sulphurous acid a purifyer? In 1884 Mr. Battua showed that it is, if the raw juice be acted upon. He tested juices from the process of a beet factory and found that .363 grams of sulphurous acid had precipitated an average of 441 grams of coloring matter and albumenoids. Here was a purification well defined and quite characteristic.

For your information I will say the method of the clarification of cane juice at present in use is as follows:

The juice after leaving the mill is passed over shelves in contact with the fumes of burning sulphur. It is then taken to the clarifiers, where milk of lime is added to a point acidity or alkalinity, which is indicated by the class of product to be produced. When high-grade sugars and molasses are desired, the juice is allowed to remain with an acidity equivalent to that of its normal acid contents, but where 96 degree sugars are being made for the purpose of sale to the refiners, a point of alkalinity is kept in the clarified juice, as it is at this point where experience has proved it is most acceptable for crystallization.

With these facts before you, it is plain that sulphur is not used as a preservative. When we use a preservative in a food product, we must have these preservatives in excess. As I have shown, we never permit the presence of sulphurous acid in excess of its combining power of those bases which the normal juices contain. Considering the advantages attained by sulphur dioxide, we find its reducing action destroys by precipitating a large per cent of the coloring matter, which if it were not used. under the present known methods of clarification would still remain in solution in the juice.

The use of lime alone causes the formation of certain organic salts of lime, which are injurious in the manufacture, but if this lime juice be sulphured, there are formed organic sulphites and the sulphite of lime, which on heating is readily precipitated.

As far as the combination in which the sulphites remaining in the molasses exists, we have been so far unable to confirm our ideas with any degree of accuracy, but the bare fact that if a syrup which has been made with the assistance of sulphur dioxide is allowed to remain exposed to the action of the atmosphere; or, if oxygen be introduced into such syrup, there is a rapid darkening of the product, which is undoubtedly the result of oxidation. With these facts before us, we must appreciate that the major portion of the sulphur present is combined with some of the organic constituents of the syrup, and we know that the major part of the organates of the corrosive acids have been found to be non-toxic in their action.

The experiments by the Board of Health of the State of Louisiana, made on a number of negroes by feeding them, along with their regular food, all the molasses they cared to consume without any compusion, was conclusive in its results, showing, from a physiological standpoint, no injurious effects upon their systems; and, until more conclusive evidence to the contrary is furnished, we hope to continue feeding our servants and ourselves on a staple food which has proved to give health rather than injury to our bodies.

Respectfully submitted,

HERBERT M. SHILSTONE, Consulting Chemist for Penick & Ford, Ltd. Mr. Shilstone also submitted the following paper: DISCUSSION ON THE SULPHUR QUESTION AT THE MEETING OF THE SOUTHERN FOOD CHEMISTS AT ATLANTA, GA.

Owing to the fact that the remarks which were made by me, after I had read my paper at the above meeting, were not properly taken down by the stenographer, who was there for the purpose, I shall attempt to make a resume of such important points as were taken up:

After reading the paper which I had prepared on the subject, and so showing that sulphur was used as a clarifying agent and not as a preservative, and that the remaining sulphites which were in the molasses or syrup were almost wholly combined with organic matter, I was asked by Mr. Brown of Tennessee, Why could not a uniform limit of contained sulphites be put on molasses and syrup? My answer was to the effect that the process of manufacture of sugar from the juice of the cane was one of concentration; that if a

syrup which showed 350 mgs. of sulphur dioxide was concentrated and crystallized to sugar and molasses, the resultant first molasses would contain about 800 mgs. of sulphur dioxide, with no sulphites showing the sugar. If this molasses is reconcentrated and more sugar taken out of it, there would be an increase to about 1,200 mgs. of sulphur dioxide in second molasses.

I furthermore brought to their attention the fact that although it was a popular idea that concentrating molasses would materially decrease the sulphites, as a matter of fact, most of our product being made in a vacuum pan, there is not the oxidation which should be expected and very little, if any, change in the per cent of sulphites. The fact that only a small per cent of the Louisiana product is from the open kettle, and that there is never any second molasses made from this process, it would be useless to consider a uniform standard based upon the reduction of sulphites.

The next question was, What percentage of sulphites was to be found in glucose or corn syrup? The answer, “Little, if any." What percentage of sulphites was to be found in refinery syrups? The answer, "About 40 mgs. per kilo, with an increase of about 40 more, depending upon the method used for the determination and the possible destruction of some of the natural sulphitdes, these showing as sulphites in the analysis."

My

Mr. Brown asked what I would expect to find in a mixture which is labeled "Corn Syrup and Refinery Syrup?" answer, "I would consider anything under 100 mgs. per kilo to be a normal amount." His inquiry on this subject was for the purpose of forming some basis for the analysis of a compound product, wherein refinery syrup should have been used, as according to the label, and low-grade Louisiana molasses was actually used. I told him that from a financial standpoint, I did not think a blender would state "Refinery Syrup" on his label and use a "second molasses," as the advantage to him in price was very much in favor of the use of refinery syrup.

Regarding the action on sulphur dioxide of several of the Northern States: as there are only a few of them which have made rulings condemning sulphur and products containing it. and as our interests were not afforded a hearing on the subject, I believe it will be possible for us to secure a hearing, and if this be allowed, I am satisfied that if the same lines be followed as in Atlanta, we will be able to have the previous ruling changed.

Respectfully, submitted,

HERBERT SHILSTONE,

Consulting Chemist. Penick & Ford, Ltd. ATLANTA RESOLUTION.

Resolved, That sulphite of soda as a preservative for meats is inhibited, that the use of benzoate of soda and of sulphur dioxide will be permitted under the same restrictions and conditions as imposed by the U. S. Department of Agriculture, that is, benzoate of soda in quantities not over 1-10 of 1 per cent and the limit in food, except in syrup and molasses, has been set for sulphite at 350 milligrams per kilogram of total free and combined SO with an addition of not over 20 per cent of the amount in a free state; in the manufacture of syrup and molasses the use of sulphur as a clarifying agent is permissible. THE NATIONAL MOLASSES REFINERS' ASSOCIATION.

N. W. Taussig, President. J. W. Hearn, Vice-President. R. B. Scudder, Sec'y-Treas.

Sugar Exchange Building. New Orleans, December 9, 1908. To the President, Washington, D. C. Sir: You chose a Board of Scientific Experts and referred to it the question of the wholesomness or wholesomeness of sulphur, benzoate of soda and saccharin in foods.

un

Pending a decision by the Board, Dr. H. W. Wiley, Chief Chemist of the U. S. Department of Agriculture, has been doing all he could to drive such foods out of the market, and declares that should the Board decide against his pronouncements, he will bring the matter into the courts.

This is nothing less than "pernicious activity," and, in
our opinion, warrants his being removed from office.
Respectfully submtted,
C. V. MOORE,

President. Louisiana Sugar Planters' Association.
J. C. MURPHY,

President Louisiana Sugar Exchange.
N. W. TAUSSIG,

President National Molasses Refiners' Association.

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