Commission on milk standards

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TREASURY DEPARTMENT

UNITED STATES PUBLIC HEALTH SERVICE
HUGH S. CUMMING, SURGEON GENERAL

COMMISSION ON MILK
STANDARDS

SUMMARY OF REPORTS OF THE COMMISSION ON
MILK STANDARDS APPOINTED BY THE
NEW YORK MILK COMMITTEE

Reprinted from the Public Health Reports, May 10, 1912, pages 673-700
August 22, 1913, pages 1733-1756; February 16, 1917, pages 271-314
January 17, 1919, pages 69-71; and December 10, 1920, pages 2955-2958

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COMMISSION ON MILK STANDARDS.

SUMMARY OF REPORTS OF THE COMMISSION ON MILK STANDARDS APPOINTED
BY THE NEW YORK MILK COMMITTEE.i

PREAMBLE.
Purposes of Milk Standards.

Proper milk standards are essential to efficient milk control by
public health authorities. In the first place, health authorities must
ascertain that the chemical composition corresponds with established
definitions of milk as food, but their more important duty is to
prevent the transmission of disease. This means the prevention of the
transmission by milk, of infant diarrhea, typhoid fever, tuberculosis,
septic throat infections, scarlet fever, diphtheria, and other infectious
diseases. In the interests of milk consumers, public health authorities
must take positive action to prevent the transmission of any of these
diseases, in addition to their duty of preserving the food value of
milk.

The milk producer is interested in proper standards for milk, and
should support a movement to secure proper standards, for the
reason that these contribute to the well-being and dignity of the
milk industry itself. Proper standards, rightly enforced, distinguish
between the good-milk producer and the bad-milk producer. This
inevitably will lead to the improvement of dairy farming, and even-
tually to an increase in the financial prosperity of the milk producer
himself through better prices for better milk. It will enable the
producer to get properly paid for the quality of milk he produces,
and thus put that industry for the first time upon a dependable basis.

The milk dealer finds the classification of milk, resulting from
milk standards, to his’ financial advantage, for the reason that it
identifies clearly first-class milk and distinguishes it from second-
class milk. Such a distinction gives to the seller of first-class milk the
commercial rewards which such milk deserves, and the official label
creates a market for first-class milk which the dealer alone is unable
to create.

For milk consumers, the setting of definite standards accompanied
by labeling with official control of the labels makes it possible to know

* These reports were published in the Public Health Reports, May 10, 1912, pp. 673-—

700; Aug. 22, 1913, pp. 1733-1756; Feb. 16, 1917, pp. 271-314 ; Jan. 17, 1919, pp. 69-71;
and Dec. 10, 1920, pp. 2955-2958,
3

4 COMMISSION ON MILK STANDARDS.

the character of the milk which is purchased, and to distinguish
good milk from bad milk. The establishment of standards for abit
ity, and of labels on retail packages indicating the quality, compels
the industry not only to purchase milk on a quality basis, but also to
sell milk on a quality basis. The selling of milk strictly on a quality
basis, which includes not only chemical composition but sanitary
character, makes it possible for consumers, by an inspection of the
label, intelligently to select milk which in quality and price is most
suitable for their needs.

Administrative Equipment.

Standards are useless unless properly guarded and enforced. The
chief objection that has been raised to a grading system for milk is
the difficulty of insuring that milk labeled as of a certain grade is
actually of that grade when sold to the consumer.

The prime requisite for efficient milk control is that health depart-
ments shall be adequately equipped with men, money, and laboratory
facilities. The commission is of the opinion that satisfactory results
can not be expected from laws when there is not sufficient appropria-
tion, and when there is no machinery for their enforcement. A sur-
vey of the money appropriated for milk control shows that in the
majority of municipalities this is entirely insufficient for public
needs..

The key to the solution of the problem of the proper use of grade
labels is the laboratory. The establishment and operation of an effi-

cient milk-testing laboratory is commonly supposed to be an item of
great expense. This, however, the commission is convinced, is a mis-
take, since there are numerous laboratories scattered all over the land,
not only private, but public, which are inexpensive and operated at
low cost. By aytione methods a large number of tests can be made
at a very low cost. Even small communities can afford to maintain
and operate such laboratories. Where for any reason it 1s not pos-
sible to do this, it has proved to be practicable for one community to
enter into laboratory arrangements with another, and even several
can combine in the use of a common laboratory.

Grading of Milk.

There is no escape from the conclusion that milk on the market
must be graded just as other commodities, such as wheat, grain, beef,
etc., are graded. The milk merchant must judge not only of the food
value but also of the sanitary characteristics of the commodity in
which he deals. There is no good reason for believing that fruit be-
ginning to decay is particularly unhealthful, but it should not be sold
on a par with sound fruit. Small apples have as much food value as

COMMISSION ON MILK STANDARDS. - 5

an equal quantity of large ones, but the latter properly command a
higher price. So, too, with milk; the high-grade product, fresh and
cold, will cost more to buy from the producer, and should sell for
more to the consumer than does the low-grade product. The commis-
sion’s most important work has been the attempt to separate milk
into grades and classes. The commission has endeavored to make its
grading system as simple as possible, and at the same time to dis-
tinguish between milks which are essentially different in their sani-
tary and other character. The commission is convinced that the ex-
perience of the last three years has fully demonstrated the value of
the grading system in the communities in which it has already been
applied, both from a public-health and an economic standpoint. The
commission believes that the grading of milk offers a satisfactory
solution for most of the sanitary and economic problems which have
hitherto prevented efficient milk control, and that it is feasible for
small communities as well as large communities to adopt a gr ading
system and to secure its benefits.

CHIEF SUBJECTS CONSIDERED.

The commission, during its deliberations over a period of nine
years and on the occasions of its meetings and the numerous meet-
ings of its subcommittees, has given attention to a great variety of
shinee

The more important conclusions it has reached are the following:

(1) Chemical Standards for Milk.

The lack of uniformity in chemical standards used by different mu-
nicipalities and States throughout the United States and Canada has
led the commission to believe that it is desirable for them to give ex-
pression to their opinion concerning proper chemical standards for
milk. The commission recognizes that chemical standards do not in-
volve public health questions excepting in so far as they safeguard
the food value of milk. Nevertheless, as milk is a food. chemical
standards are necessary for defining its nutritive value.

The chemical standards sup pested are the work of a special com-
mittee, composed of chemists, which has carefully considered the
natural composition of milk, as well as the Federal and State stand-
ards already established. The standard of 3.25 per cent fat and 8.5
per cent solids-not-fat, here proposed, is in accordance with the
recommendations of the Association of Official Agricultural Chem-
ists, and has been adopted by the United States Department of
Agriculture and by a larger number of States than has any other
standard. (The word “standard” used in connection with milk is
not intended to imply excellence, but simply to express the lowest

6 COMMISSION ON MILK STANDARDS.

possible standard or limit that the law permits for a pure or normal
milk. The same meaning applies to the word used in connection with
milk products.)

The Babcock test makes easily practicable the determination of fat
and solids-not-fat in milk. Such examinations of milk can be readily
adopted and executed by any health board laboratory at a very mod-
erate expense. It is believed that such chemical standards as are
suggested will help to raise the standards of dairying in this country,
and that the provision regarding substandard milk is a liberal one.

Cow’s milk.—Standard milk should contain not less than 8.5 per
cent of solids-not-fat and not less than 3.25 per cent of milk fat.

Skim milk.—Standard skim milk should contain not less than 8.75
per cent of milk solids.

Cream.—Standard cream should contain not less than 18 per cent
of milk fat, and should be free from all constituents foreign to
normal milk. The percentage of milk fat in cream over or under
that standard should be stated on the label.

Adjusted milks —On the question of milks and creams in which
the ratio of the fat to the solids-not-fat has been changed by the
addition to or subtraction of cream or milk fat, the commission has
hesitated to take a position. Om the one hand, they are in favor of
every procedure which will increase the market for good milk and
make the most profitable use of every portion of it. On the other,
they recognize the sensitiveness of milk, the ease with which it is
contaminated, and the difficulty of controlling such processes as
standardizing, skimming, homogenizing, souring, adjusting, etc.,
so as to prevent contamination and the use of inferior materials.
On this subject the commission passed a resolution presented by a
special committee, as follows:

The committee believe that it is probably necessary to admit standardized
and adjusted milk. They believe that such manipulation should be controlled
and that such milk should be distinctly labeled as to its modifications.

Milk in which the ratio of the fat to the solids-not-fat has been changed by
the addition to or subtraction of cream should be labeled ‘‘ adjusted milk’;
the label should show the minimum guaranteed percentage of fat and should
comply with the same sanitary or chemical requirements as for milk not so
standardized or modified.

The committee very carefully considered the subject of the agitation
which has taken place regarding percentage of solids-not-fat, owing
to the fact that in some large cities much of the milk contains less
than 8.5 per cent solids-not-fat. While the commission is disposed
to admit that these conditions may exist, yet it believes that these
conditions can be remedied, if not immediately, at least gradually.
On the other hand, experience has shown that to lower the standard
would, in a few years, result in the lowering of the general quality

COMMISSION ON MILK STANDARDS, 7

of the milk placed on the market, since commerce always tends to
approach the minimum standard. The commission therefore thinks
it is unwise to reduce the standard for solids-not-fat below the per-
centage of 8.5. In those communities where such a standard can
not be rigidly enforced at the present time, the commission suggests
that the standard be gradually applied.

Regulation of market milk on basis of guaranteed percentage com-
position.—(a) Sellers of milk should be permitted choice of one of
two systems in handling market milk. They may sell milk, first,
under the regular standard; or, second, under a guaranteed state-
ment of composition.

(6) Any normal milk may be sold if its percentage of fat is
stated. In case the percentage of fat is not stated, the sale should be
regarded as illegal unless the milk contains at least 3.25 per cent of
milk fat.

(c) As a further protection to consumers, it is desirable that when
the guaranty system is used there be also a minimum guaranty of
milk solids-not-fat of not less than 8.5 per cent.

(d) Dealers electing to sell milk under the guaranty system should
be required to state conspicuously the guaranty on all containers in
which such milk is handled by the dealer or delivered to the con-
sumer.

(e) The sale of milk on a guaranty system should be by special
permission obtained from some proper local authority.

(2) Bacteria and Bacterial Testing.

Bacteria and bacterial testing have undoubtedly occupied more of
the commission’s time than any other subject, this topic being con-
sidered at each of its meetings. Every phase of the relationship of
bacteria to the sanitary character of milk, as well as to the infec-
tious diseases transmissible by milk, has been discussed by the seven
bacteriologists who are members of the commission. The signifi-
cance of bacteria in milk and methods of bacteria] testing have been
considered in detail, not only from the personal standpoint of the
bacteriologist but from the administrative standpoint of the eight
health officers who are members of the commission, as well as the
two agricultural experts. Because of frequent conferences with
members of the dairy industry, as well as a knowledge of the action
taken by municipalities on this subject, it is believed that all phases
of the relationship of bacteria to milk have been impartially con-
sidered and that the conclusions reached fairly represent the place
which bacterial testing should occupy.

8 COMMISSION ON MILK STANDARDS.

The commission recognizes that the number of bacteria in milk is
controlled in the majority of instances by three factors: Dirt, tem-
perature, or age. Only in the minority of instances are the bac-
teria of specific diseases present. The routine laboratory methods
for examining milk have, therefore, as their chief purpose the control
over dirt, temperature, and age. The difficulties of detecting the
specific bacteria of disease by laboratory methods prevent labora-
tories from undertaking such detection as a routine. For this reason,
laboratory methods are as yet of little value in safeguarding milk
against specific diseases. The only practical way for protecting
milk from infection by the bacteria of infectious diseases is by
medical, veterinary, and sanitary inspection, and by pasteurization.
Nevertheless, the commission believes that large numbers of bacteria
that are not specific disease germs have a health significance.

The routine laboratory methods for determining the total numbers
of bacteria in milk are believed to furnish a general indication of the
safety of milk. Small numbers indicate fresh milk produced under
clean conditions, and kept cool; and such milk is safer than milk
containing large numbers of bacteria, which is either dirty, warm,
or stale. In addition to this, the relation which large numbers of
bacteria bear to the sanitary character of milk is shown by certain
facts, among which the following are worthy of mention:

Relation of large numbers of bacteria to infant mortality.—The
commission believes that the numbers of bacteria in milk have a re-
lation to the infant mortality, for the following reasons:

(a) Evidence furnished by clinical observations of groups of
children fed on milk containing small numbers of bacteria and
large numbers of bacteria shows a higher death rate in the latter
than in the former.

(>) In general, a reduction in infant mortality in cities results
from a substitution of milk containing small numbers of bacteria for
milk containing large numbers of bacteria.

(c) Bacteria causing no specific intestinal infections in adults may
cause infant diarrhea. and milk containing large numbers of bacteria
more often contains species capable of setting up intestinal inflamma-
tion in infants than milk containing small numbers of bacteria.

Bacterial counts and decency—On this subject the commission
passed the following resolutions:

(a) Because high bacterial counts indicate milk is either warm,
dirty, or stale, the bacterial count is an indicator of decency in milk
character, entirely apart from its significance as an indicator of the
safety of milk.

(6) In determining the sanitary character of milk and the grade
in which it belongs, decency must be considered as desirable for its
‘own sake, entirely apart from the consideration of safety. Decency

COMMISSION ON MILK STANDARDS. 9

is important as a characteristic of foods and drinks, because it gives
pleasure to the consumption of food, while the lack of decency means
distaste, displeasure, and even disgust.

(c) The bacterial count is a sufficiently accurate measure of de-
cency to justify the health officer in condemning milk with a high
bacterial count because it is lacking in this characteristic.

Bacteriological laboratory testing of milk.—On the subject of lab-
oratory examinations of milk for bacteria the commission believes
that the interests of public health demand that the control of milk
supplies, both as to production and distribution, should include regu-
lar laboratory examinations of milk by bacteriological methods.
They stated by resolution that—

Among present available routine laboratory methods for determining the
sanitary quality of milk the bacterial count occupies first place, and that bac-
terial standards should be a factor in classifying milk of different degrees of
excellence,

The adoption and enforcement of bacterial standards will be more effective
than any other one thing in improving the sanitary character of public milk
supplies. The enforcement of these standards can be carried out only by the
regular and frequent laboratory examinations of milk for the numbers of bac-
teria it may contain.

It is of the utmost importance that standard methods should be adopted
by all laboratories for comparing the bacterial character of milks, since by this
means only is it possible to grade and classify milks and properly enforce
bacterial standards.

Concerning the methods which should be used by milk laboratories
for determining the numbers of bacteria, the commission unanimously
resolved:

That there be adopted as standards for making the bacterial count the stand-
ard methods of the American Public Health Association Laboratory Section.

One of the chief objections raised against pasteurization is the
claim that it is frequently employed to cover filthy methods, the milk
producer using less care in his methods if he knows that the milk is
to be subsequently pasteurized. To meet this objection the commis-
sion believes there should be bacterial standards for raw milk as well
as bacterial standards for pasteurized milk. In the case of pasteur-
ized milk, standards should be required of the milk before pasteuriza-
tion as well as after pasteurization.

Reliability of bacterial tests—The commission has considered the
numerous criticisms that have been raised as to the unreliability of
bacteriological analyses and has made extensive inquiry as to the
force of these criticisms. An opinion concerning the reliability of
laboratory tests for numbers of bacteria has been reached, based on
voluminous statistics secured for the most part by groups of observers
working together. as well as by individuals, One of these researches
31901°—21——-2 "

10 COMMISSION ON MILK STANDARDS.

alone carried out by members of the commission, in cooperation with
others, included the testing of over 20,000 samples of milk. In other
instances, repeatedly the same sample of milk was tested 100 times.
Some variations in the analysis of duplicate samples are inevitable,
owing to the fact that the bacteria are not in solution, but are floating
in the milk more or less clustered together in clumps, each of which
will count only as a single colony. Under such conditions, only an
approximate agreement can be expected.

The results of extensive study justify the commission in the con-
clusion that the analysis of duplicate samples of milk made by routine
methods in different laboratories may be expected to show an average
variation of about 28 per cent, with occasional samples of wider
variation. In some good laboratories the variation may not be
greater than 10 per cent. Variations in results diminish with the
numbers of samples analyzed. If five samples of the same milk are
tested, the results may be relied upon as fairly accurate, and always
sufficiently accurate to place any particular milk supply unhesitat-
ingly in grade A, B, or C. The object of bacterial tests of milk
samples for the numbers of bacteria should be primarily to deter- .
mine the sanitary character of the milk supply from which the sample
is taken, rather than the character of a single sample of milk. It is
strongly urged by this commission that no grading of milk should
be made upon the analysis of single samples, and that no prosecu-
tions or court cases should be brought upon the bacterial analysis of
a single sample of milk.

Interpretation of bacterial tests —The commission has put its opin-
ions on this subject in the form of resolutions, as follows:

Whereas milk is one of the most perishable foods, being extremely susceptible
to contamination and decomposition ; and

Whereas the milk consumer is justified in demanding that milk should be
elean, fresh, and cold, in addition to having the element of safety; and

Whereas milk which is from healthy cows and is clean, fresh, and which has
been kept cold, will always have a low bacterial count; and

Whereas milk that is dirty, stale, or has been left warm will have a high bacte-
rial count: Therefore it is resolved :

First, That the health officer is justified in using the bacterial count as an
indicator of the degree of care exercised by the producer and dealer in securing
milk from healthy cows and in keeping the same clean, fresh, and cold; and

Second, That the health officer is justified in condemning milk with a high
bacterial count as being either unhealthy or decomposed, or containing dirt,
filth, or the decomposed material as a result of the multiplication of bacteria
due to age and temperature.

Third, That the health officer is justified in ruling that large numbers of
bacteria are a source of possible danger, and that milk containing large numbers
of bacteria is to be classed as unwholesome, unless it can be shown that the
bacteria present are of a harmless type, as, for example, the lactic acid bacteria
in buttermilk or other especially soured milks,

COMMISSION ON MILK STANDARDS. 11

Grading by the bacterial count—Concerning the number of tests
which should be made in order to determine the grade of a milk sup-
ply, the commission recommends that the grade into which a milk
falls shall be determined bacteriologically by at least five consecutive
bacterial counts, taken over a period of not less than one week nor
more than one month, and that at least four out of five of these counts
(80 per cent) must fall below the limit or standard set for the grade
for which classification is desired.

The grading of milk has necessarily been based on its sanitary char-
acter, primarily as determined by the bacterial test. The enforcement
of grading, therefore, requires the application of the bacterial test in
a manner sufficiently comprehensive to fairly determine the sanitary
character of milk so that it may be assigned to the grade in which it
belongs. Such an administrative system greatly modifies the former
conception of milk inspection by public health officials. The inspec-
tion service under the grading system becomes subordinate to the
bacterial laboratory, or at least must look to the bacterial laboratory
asa guide. If bacteria! tests are recognized as an indication of the
sanitary character of milk, then the bacterial laboratory tests should
precede the dairy inspection, since they will point out to the dairy in-
spector the location of insanitary milk. In the enforcement of the
grading system, therefore, the milk inspection service should be re-
organized in such a manner that the bacterial laboratory makes its
tests first, in order to determine the sanitary character of the various
milks offered for sale on the city market, and the inspection service
then takes up the task of discovering the location and causes of the
defects which the laboratory has discovered, and of remedying them.
The laboratory service and inspection service consequently must be
centralized under one head and their work thoroughly coordinated in
order to give the greatest economy and efficiency.

Bacterial standards for cities of different sizes.—In establishing the
bacterial standards for a city it is important to take into consider-
ation the necessary age of the milk, the distance it is hauled, and the
methods employed in its hauling, in addition to the sanitary condi-
tion of the milk at its source. It will always be possible for a com-
munity having very few dairies, easily controlled, which consumes
milk produced within its own limits, or within transportation of 12
hours or less from the sources of supply, to insist upon and maintain a
better bacterial standard than can a city where the milk is hauled
many miles into town to be consumed within 24 hours after it is
produced from numerous dairies difficult to control. The small city,
for these reasons, can and should always maintain a better bacterial
standard than the large city.

12 COMMISSION ON MILK STANDARDS.

Microscopic exammmnation.—Under certain conditions the examina-
tion of milk for bacteria by the microscopic method serves a useful
purpose. In its favor it has the advantage of quick and immediate
results, which, in the hands of reliable workers, have proved to agree
remarkably well with the results obtained by the plate method. At
times it gives useful information as to the types of bacteria present.
On the other hand, the microscopic method fails to distinguish be-
tween dead and living bacteria, and therefore its value in the exami-
nation of pasteurized milk is uncertain. Its chief value has been in
securing quick information regarding the character of raw milk, and
for this reason it is most useful at the producing and shipping end of
the line rather than at the city end.

The commission received reports (meeting of Dec. 8, 1918) of
special tests made in many municipal and private laboratories on 100
samples of milk taken from the same quart bottle, by the standard
methods for determining the numbers of bacteria in milk recom-
mended by the laboratory section of the American Public Health
Association, and, basing its opinion on these and previous reports,
the commission passed the following resolution:

The commission believes that experience has shown that the present standard
methods of the laboratory section of the A. P. H. A. for making the bacterial
test of milk, in the hands of properly trained workers, are satisfactory for the
control of the sanitary character of raw milk on the efficiency of pasteurizing
machines for destroying bacteria, and for the enforcement of regulations for

milk control by such grades and standards as have been recommended by this
commission,

(3) Pasteurization.

The pasteurization of milk has been discussed at every meeting held
by the commission. Its effect on bacteria, its effect on milk, its effect
on public health, the questions of time and temperature and efficient
control have all been repeatedly and carefully considered in detail.
It is believed that the commission has not neglected to take into ac-
count any of the important contributions which have been made to
modern knowledge on this subject. In connection with pasteuriza-
tion the commission has also carefully considered the subject of the
degrees of safety furnished to milk by the tuberculin testing of
cattle and medical inspection of dairy employees.

After a thorough consideration of the various times and tempera-
tures used, and different forms of apparatus recommended by various
authorities, the commission decided upon the following definition
of pasteurization:

That pasteurization of milk should be between the limits of 140° F. and
155° F, At 140° F. the minimum exposure should be 20 minutes, For every

COMMISSION ON MILK STANDARDS. 13

degree above 140° F. the time may be reduced by 1 minute. In no case should
the exposure be for less than 5 minutes,

In order to allow a margin of safety under commercial conditions,
the commission recommends that the minimum temperature during
the period of holding should be made 145° F., and the holding time
30 minutes,

Regarding the methods of pasteurization, the commission believes
that pasteurization in bulk, when properly carried out, has proved
satisfactory, but that pasteurization in the final container is prefer-
able. ;

The commission thinks that pasteurization is necessary for all milk,
excepting grade A raw milk. The majority of the commissioners
voted in favor of the pasteurization of all milk, including grade A
raw, but since the action was not unanimous the commission recom-
mended that the pasteurization of grade A raw milk be optional.

The process of pasteurization should be under efficient supervision.
The supervision should consist of a personal inspection by the milk
inspector. The intervals between inspections should be not more than
one month. The inspector should score the pasteurizing plant by a
score card.

Specimens of milk for bacterial analysis should be taken at the
different stages in pasteurization and subsequent handling.

All plants handling 1,000 quarts of milk or more a day should be
required to be equipped with automatic temperature regulators, flow
regulators, and recording thermometers. The records of these must
be examined by the department of health not less often than once a
month.

Where pasteurization is done with small apparatus not so equipped,
the proprietor should be required to examine the temperature of the
milk in the heater at the first and last of each run, and keep a record
of such temperatures, which record shall be submitted to the de-
partment of health not Jess often than once a month.

For the use of small dealers in cities and small producers for towns
and villages, efficient pasteurizers costing less than $200 are available.
The commission, therefore, thinks that milk ordinances for towns and
villages, as well as for large cities, and also State milk laws, should
provide compulsory pasteurization, except for grade A raw milk.

The efficiency of pasteurization should be controlled by bacterial
tests before and after heating.

RESOLUTION PASSED AT THE MEETING OF MAY 21, 1920.

Experience with the pasteurization of milk by the use of the time
and temperature recommended by this commission has justified in
every way the selection of the time and temperature which were

14 COMMISSION ON MILK STANDARDS.

recommended, and the commission wishes, therefore, to confirm the
original report on this subject by stating that so far as the commis-
sion is aware, there is no reason why it should change the recom-
mendation originally made regarding the proper time and tempera-
ture of pasteurization of milk. The recommendation originally made
and published in the Public Health Reports, February 16, 1917, was
as follows:

(a) That pasteurization of milk should be between the limits of 140° TF’. and
155° F. At 140° F. the minimuni exposure should be 20 minutes. For every
degree above 140° F. the time nray be reduced by 1 minute. In no case should
the exposure be for less than 5 minutes.

(b) In order to allow a marign of safety under commercial conditions, the
commission recommends that the minimum temperature during the period of
holding should be made 145° F. and the holding time 30 minutes.

Scurvy and pasteurization —The commission has assumed that the
low temperature of 145° F. for 30 minutes, as recommended by this
commission for pasteurization, destroys none of the food constituents
of milk. Inquiry conducted by the New York City Department of
Health into the records of the infant milk depots, where sometimes
over 25,000 infants are fed daily on pasteurized milk, appears to bear
out this assumption. In view of the fact, however, that recent hos-
pital experimental studies suggest that an exclusive diet of pasteur-
ized milk may give rise to a subacute scurvy or similar nutritional dis-
ease in infants, which was entirely prevented, and even cured, by the
feeding of orange juice or other antiscorbutic food, the commission
recommends that orange juice be added to the diet of infants that are
fed on pasteurized milk. The commission wishes also to reaffirm its
advocacy of the adoption of pasteurization by municipalities as a
public-health measure.

In 1917 the commission adopted a resolution to the effect that in
its opinion the pasteurization of milk at 145° F. for 30 minutes
destroys none of its food constituents. Since that time there has
been much careful research on the relation of scurvy to the lack
of a protective substance in the food. It has been demonstrated to
the satisfaction of all of the most eminent authorities in nutrition
that scurvy is due to the lack of a specific dietary factor which
is easily destroyed by heating, and that milk which has been pas-
teurized has lost, in part at least, its protective action against this
disease.

It has likewise been demonstrated that there may be pronounced
differences in the value of fresh, unheated milks in their antiscorbutic
value, depending on the nature of the diet of the cow or lactating
woman. The antiscorbutic substance is found abundantly only in
fresh fruits, vegetables, green grass, and other forage. Cooked foods,

COMMISSION ON MILK STANDARDS. £5

with certain exceptions, such as tomatoes, are of little value, and the
milk of a mother whose diet consists largely of cooked or dried or
preserved foods will not protect her infant against this disease unless
some substance rich in antiscorbutic properties be included. The
milk of cows will be more effective as an antiscorbutic food when they
are fed green foods.

In view of these new discoveries concerning the possibility of the
variation of the nutritive value of milks, to some extent, with the
diet and the seasons, and in view of the possible reduction of the
food value of milk, with respect to the antiscorbutic factor, in the
process of pasteurization, the commission recommends that orange
juice or tomato juice or other antiscorbutic food be added to the
diet of infants, especially those artificially fed. The commission
wishes also to reaffirm its advocacy of the adoption of pasteurization
by municipalities as a public health measure.

(4) The Tuberculin Testing of Dairy Cows.

The commission has noted recent developments in connection with
the manner of administering tuberculin as a diagnostic agent, and
goes on record as approving the use of tuberculin by the usual sub-
cutaneous method, always, however, in connection with physical
diagnosis, and with due regard to the methods prescribed by the
United States Bureau of Animal Industry. Other methods of using
tuberculin should be regarded still as under judgment.

The commission believes that health officers should encourage the
use of tuberculin as an ideal diagnostic agent when in proper hands,
and extend its use as rapidly as possible, realizing its practical limita-
tions owing to the enormous number of cattle and their migrations
and the limited number of veterinarians qualified to use this test.

It should be remembered also that tuberculin testing is a means of
meeting only one of the many problems of milk control.

(5) Grades of Milk.

The commission believes that all milk should be classified by divid-
ing it into three grades, which shall be designated by the letters of the
alphabet. It is the sense of the commission that the essential part is
the lettering and that all other words on the label are explanatory.
In addition to the letters of the alphabet used on caps or labels, the
use of other terms may be permitted so long as such terms are not the
cause of deception. Caps and labels shall state whether milk is raw
or pasteurized. The letter designating the grade to which the milk
belongs shall be conspicuously displayed on the caps of bottles or the
labels of cans.

16 COMMISSION ON MILK STANDARDS.
The requirements for the three grades shall be as follows:

GRADE A.

Raw milk.—Milk of this class shall come from cows free from disease, as de-
termined by tuberculin tests and physical examinations by a qualified veteri-
narian, and shall be produced and handled by employees free from disease, as
determined by medical inspection of a qualified physician, under sanitary condi-
tions such that the bacterial count shall not exceed 10,000 per cubic centimeter
at the time of delivery to the consumer. It is recommended that dairies from
which this supply is obtained shall score at least 80 on the United States Bureau
of Animal Industry score card.

Pasteurized milk.—Milk of this class shall come from cows free from disease,
as determined by physical examinations by a qualified veterinarian, and shall
be produced and handled under sanitary conditions such that the bacteria count
at no time exceeds 200,000 per cubic centimeter. All milk of this class shall be
pasteurized under official supervision, and the bacterial count shall not exceed
10,000 per cubic centimeter at the time of delivery to the consumer. It is recom-
mended that dairies from which this supply is obtained shall score at least 65
on the United States Bureau of Animal Industry score card.

GRADE B,

Milk of this class shall come from cows free from disease, as determined by
physical examinations, of which one each year shall be by a qualified veteri-
narian, and shall be produced and handled under sanitary conditions such that
the bacterial count at no time exceeds 1,000,000 per cubic centimeter. All milk
of this class shall be pasteurized under official supervision, and the bacterial
count shall not exceed 50,000 per cubic centimeter when delivered to the con-
sumer.

It is recommended that dairies producing grade B milk should be scored, and
that the health departments or the controlling departments, whatever they may
be, strive to bring these sources up as rapidly as possible.

GRADE C,

Milk of this class shall come from cows free from disease, as determined by
physical examinations, and shall include all milk that is produced under condi-
tions such that the bacterial count is in excess of 1,000,000 per cubic centimeter.

All milk of this class shall be pasteurized, or heated to a higher temperature,
and shall contain less than 50,000 bacteria per cubic centimeter when delivered
to the consumer.

Whenever any large city or eommunity finds it necessary, on account of the
length of haul or other peculiar conditions, to allow the sale of grade C milk,
its sale shall be surrounded by safeguards such as to insure the restriction of
its use to cooking and manufacturing purposes.

Grades for small cities and towns—This commission recognizes
that because of climate, size of the community, nearness to the sources
of supply, ease of transportation, and progress already made in im-
proving the general milk supply, and in educating the dairymen and

COMMISSION ON MILK STANDARDS. 17

the public, different communities are in position to secure varying
degrees of excellence in their standards for the grades of milk. This
commission, therefore, urges that its standards for grades A, B, and
C milk be regarded as minimum standards, and that any community
may adopt higher requirements for its grades if its conditions make
this feasible and desirable.

As a guide to health officers in the establishment of grades best
adapted for their local communities, the following general broad prin-
ciples are offered:

(1) A careful prelimnary survey of the milk situaton should be made before
the requirements of the several grades are adopted.

(2) No matter how excellent the general milk supply of a community, it is
not all of a single standard of excellence, hence there are actually different
grades of milk in every community, and the recognition of such grades is always
advantageous.

(3) Grades in any community should always be such as to separate into two,
or at most three, classes the milk supply of that special community. Where little
or nothing has been done toward improving the general milk supply, it may be
desirable to adopt temporary grades (but not below the minimum requirements
suggested by this commission), with a time limit as to when more rigid require-
ments for the grades will be enforced.

(4) Grades as adopted in any community should be such as not, under any cir-
cumstances, to sanction the sale of milk below the minimum standards which it
is feasible for that community to require.

’ (5) Whatever departures are made by any community from the exact definition
of grades as recommended by this commission, several fundamental principles are
recognized by the commission as of universal application, and from these there
should be no variation. These fundamental principles are:

(a) Grade A milk, in a general way, is milk which complies with requirements
of such character and degree that, for all practical purposes, no real advantage
would be gained by further and higher requirements. The standards for this
grade should therefore be placed high enough to attain this end, but not so high
as to limit too greatly the supply, or, through unduly raising the price to the
consumer, to limit too greatly the demand.

(b) Grade B milk is all the remaining milk of the community which is suitable
for drinking purposes, after pasteurization, but which does not comply with the
high requirements for grade A milk.

(c) Grade C milk is milk which falls below the minimum requirements for
milk suitable for drinking purposes, even after pasteurization. Its use must be
confined to cooking and manufacturing purposes. Recognition of this grade of
milk is not recommended by this commission except in communities in which
such recognition is an economic necessity.

(6) The fundamental objects in grading milk are:

(a) To aid in making safe for human consumption all milk which can legally
be sold for drinking purposes.

(b) To distinguish between classes of milk which, while all are safe, are of
different degrees of excellence in respect to cleanliness and care in handling.

Each community should, therefore, endeavor to grade its milk sup-
ply so as best to attain these objects without departure from the broad
general principles above laid down.

31901°—21——3

18 COMMISSION ON MILK STANDARDS.
(6) Infected Udders.
RESOLUTION PASSED AT THE MEETING OF MAY 21, 1920.

There is occasional danger to human beings from infected udders
of dairy cows when the udder infection is due to pathogenic bacteria
of human origin. The danger from udder infection when the bacteria
are of bovine origin has not yet been determined and is uncertain,
with the exception of infections from bovine tuberculosis, which are
known to be dangerous to human beings. Every effort should be
made to exclude udder infections from dairy herds. Pasteurization
is a protection because it destroys the bacteria of udder infections in
milk.

(7) Cream.

Cream should be classified in the same grades as milk, in accordance
with the requirements for the grades of milk, excepting the bacterial
standards, which in 18 per cent cream shall not exceed five times the
bacterial standard allowed in the same grade of milk.

Cream containing other percentages of fat shall be allowed a modi-
fication of this required bacterial standard in proportion to the change
in fat.

(8) Butter.

There is evidence that much of the butter offered for sale on city
markets is produced from cream of an inferior grade. The source of
such cream is in many instances farms where dairying is only inci-
dental and there are no facilities for sanitary care or refrigeration.

The stations where this cream is gathered and the plants where it
is manufactured into butter are often in a most insanitary condition.
It is believed that sanitation in the production and handling of fluid
milk is far in advance of sanitation in the butter industry. It is the
opinion of the commission that steps should be taken at once to bring
about a reform in the production and handling of butter, and that
this can best be done by the establishment of standards and grades
which will distinguish between the superior and inferior product.
The commission has deliberated on the subject of butter for a period
of three years, and has made a detailed study through several of its
standing committees, in addition to conferences with leading repre-
sentatives of the industry itself. The conclusion of the commission
on this subject is as follows:

Definition—Standard butter is the clean, nonrancid product made by gather-
ing in any manner the fat of fresh or ripened cream or milk into a mass, which
also contains a small portion of other milk constituents, with or without salt,
or added harmless coloring matter, and contains not less than 82 per cent of
milk fat.

COMMISSION ON MILK STANDARDS. 19

Butter should be graded as to its sanitary quality and market score, and this
commission recommends such methods as were recently adopted by law in
Minnesota and Jowa, whereby the grading of butter on such a basis will be
started aS a voluntary matter.

In the interest of public health, cream used in the manufacture of butter
should be pasteurized before being used.

Grade A butter should be made from grade A milk or cream.

Grade B butter should be made from grade B milk or cream.

The sale of butter should be restricted to the product obtained from milk or
cream that has been produced in such a manner that it could be sold when
fresh as grade A or grade B milk or cream, as defined by this commission. Such
milk or cream shall be handled, before manufacture, under strictly sanitary
conditions by persons free from communicable disease.

If the sale of butter that is made from an inferior grade of milk or cream
is permitted, such milk or cream should in all cases be pasteurized, and the
butter properly labeled.

If butter is manufactured from rectified milk or cream, the fact shall be so
stated on the label, and such butter should be considered as of the same class
as renovated butter. Such butter shall be classified as grade C.

All containers in which butter is sold shall be marked with the grade of the
poorest milk or cream that is used, with the name and location of the plant at
which it is manufactured, and with the date of manufacture.

(9) Ice Cream.

The commission has had the subject of ice cream under considera-
tion for three years. It has been in the hands of a special committee.

In 1914 several series of bacteriological examinations of ice cream
were carried out by the bacteriologists of the commission, all of whom
handed in reports to the commission showing the character of ice
cream from samples taken in their own localities. There was also
made available for the commission special work done on this subject
by the Department of Agriculture at Washington, and by a number
of public health authorities.

The commission voted that ice cream shall be regarded as a food
rather than a confection in the sense of the pure-food law. The com-
mission also voted that the milk and cream used in the manufacture
of ice cream should conform to the standards recommended by the
commission for milk and cream; also, that all milk and cream used in
the manufacture of ice cream be pasteurized.

Concerning the definition of ice cream, which was discussed at
several meetings, the commission decided upon the following:

Ice cream is a frozen product made from pasteurized cream and sugar, or
pasteurized cream and pasteurized milk and sugar, and shall contain not less
than 8 per cent milk fat. It shall not contain any preservatives, neutralizing
agent, saccharine, renovated or process butter, fats, or oils foreign to milk or to
other ingredients allowed. It may contain wholesome eggs, harmless coloring
matter, flavoring, sound, clean, mature fruits and nuts, pastries, and approved
thickening not to exceed 0.5 per cent.

20 COMMISSION ON MILK STANDARDS.

Ice cream should be kept frozen until dispensed. Synthetic cream
(the product made by emulsifying homogenized butter with milk or
skim milk) should not be recognized for ice cream or other cream pur-
poses unless the methods and ingredients used be approved by the
proper authorities.

Health officers are advised to allow nothing to be sold under the
name of ice cream unless it comes under the above definition, with the
further provision that it be manufactured and handled in a sanitary
manner, the method of determining proper sanitation to be controlled
by local officials.

Where there are no bacterial standards, the bacterial content should
be used as a guide in checking sanitary conditions.

The use of substitutes for cream, such as emulsified fats other than
milk fats, should not be allowed for ice cream or other cream purposes.
If used, the finished product should not be labeled ice cream.

Grading.—Concerning the character of the products used in ice
cream, the commission decided to recommend that milk products used
in the manufacture of ice cream be restricted to the products of the
erade A and grade B classes.

Grade A ice cream should be made from grade A milk or cream, and
the finished product should contain not more than 100,000 bacteria per
cubic centimeter.

Grade B ice cream should be made from milk or cream not lower
than grade B, and the finished product should contain not more than
1,000,000 bacteria per cubic centimeter.

The commission recommends the use of a suitable score card in
grading the sanitary condition of ice-cream factories.

A suggested score card is included in Appendix 1 of this report.

(10) Condensed Milk.

The commission recognizes that in the manufacture of condensed
milk, evaporated, powdered, and condensed milk products, the sani-
tary character of the raw milk used affects not only the keeping quali-
ties but also the safety and decency of the finished product. It is
clearly to the best interests of the public and the condensed-milk in-
dustry that condensed milk should be so labeled that the product pre-
pared from fluid milk of a good quality may be distinguished from
that prepared from inferior milk.

The commission therefore recommends the passage of Federal,
State, and municipal legislation which will permit the manufacturer
to state upon the label that his product has been prepared from grade
A milk, and he shall be protected in the use of such a label,

COMMISSION ON MILK STANDARDS. A) I
(11) Skim Milk.

The commission passed a resolution regarding the chemical stand-
ards for skim milk at one of its earliest sessions, recommending that
skim milk should contain not less than 8.5 per cent of milk solids not
fat.

In addition to this, regarding the food value of skim milk, the com-
mission recommends that:

Whereas the pressure of the cost of living is increasing rapidly, and vast quan-
tities of nutritious and available food are now going to waste, and laws pro-
hibiting the sale of skim milk have no public-health significance; therefore, the
commission recommends that the use of skim milk as a food be approved, and
urges the repeal of laws wherever they exist that prohibit the sale of skim milk
as a food.

(12) Buttermilk.

Concerning buttermilk the commission considered the subject at
three of its sessions. As a definition of buttermilk the commission
suggests:

That the sale of buttermilk should be restricted, first, to the product resulting
from the churning of milk or cream that is produced under such conditions that
when fresh it could be sold as grade A or grade B milk or cream, as such grades
have been defined by this commission ; or, second, to the product resulting from
the skimming, souring, or treatment in any way of grade A or grade B milk,
so that it resembles buttermilk (the true character of such imitation or artificial
buttermilk to be distinctly stated on the container in every case), provided that
all such buttermilk shall be handled during and after manufacture in a sani-
tary manner approved by the local health authorities, and that it shall be kept
at a temperature below 50° F.. from the time of manufacture until delivered to
the consumer.

The commission recommends that all milk, cream, or skim milk
entering into the manufacture of buttermilk be pasteurized, unless it
can be shown that such milk or cream corresponds to grade A raw
milk.

All buttermilk should be sold in bottles or cans that are properly
sealed and labeled, with the name of the manufacturing plant, with
either the day or date of manufacture, with the grade of milk from
which it was manufactured, and with a statement as to whether it was
manufactured from a raw or pasteurized product, and whether it was
artificially or naturally prepared.

(13) Dry and Powdered Milks.

The use of powdered whole milk, skim milk powder, condensed
or evaporated whole milk or skim milk, butter fat or other fats and
water, and of machines for recombining, mixing, or emulsifying these

o2 COMMISSION ON MILK STANDARDS.

materials for the production of manufactured milk or cream was
considered by a special committee, including some of the food chemists
of the commission. Their special report on these subjects was adopted
by the commission and was as follows: .

1. Since the application of the term “ synthetic ” to mixtures such
as those under consideration is not entirely consistent with the ac-
cepted scientific use of the term and is likely to cause confusion, we
recommend that the use of the term “synthetic” be discouraged and
that the commission recommend the terms “recombined milk,” “ re-
constituted milk,” on the labels of products made entirely from milk
constituents, and “ artificial milk ” or “ milk substitute ” on the labels
of products in which any other fat is substituted in whole or in part
for milk fat. Products which do not contain the proteins and
mineral elements of milk should not be entitled to the use of any
designation of which the word milk is a part.

2. 'The committee moves the adoption of the following resolution:

Whereas recent investigations in the science of nutrition have fully demon-
strated the unique value of milk as a food and the intimate relation between
adequate milk consumption and the support of normal growth or maintenance
of health and vigor: Be it
Resolved, That the commission urge upon all concerned with the production

and distribution of milk, whether as producers, dealers, or public health and
food control officials, the great importance of bringing into human consumption
the largest possible proportion of all wholesome milk products. and to this end
recommends that the sale of such products as recombined milk should not be
hampered by any restrictions beyond those absolutely necessary for the preven-
tion of fraud and the protection of health.

3. In the case of recombined milk made exclusively from cream or
butter and milk or skim milk, fresh, condensed or dried, the materials
having always been maintained in sound condition and not subjected
to unnecessary heating, the interests of the consumer, in our opinion,
demand nothing further than that the product as delivered to the
purchaser shall meet all the requirements as to cleanliness, bacterial
count, and chemical composition of fresh milk of the same grade or
class, and shall be labeled in a manner that will correctly indicate
its true character.

RESOLUTIONS PASSED AT THE MEETING OF MAY 21, 1920.

The commission adopted the following report on the subject of
dried and remade milks:

Whereas the commission is fully convinced that an increased consumption of
milk in its various forms would be highly advantageous to the public health;
and

Whereas the production and sale of dried and remade milk tends to increase,
stabilize, and conserve the milk supply; and

Whereas all evidence now available favors the view that properly prepared
dried milk may be regarded as of nutritional value equal to milk of light grade,
and that the vitamine content of dried milk and pasteurized milk is substan-
tially the same; Therefore be it

COMMISSION ON MILK STANDARDS. 23

Resolved, That the commission urge upon the health and food control officials
a liberal attitude such as shall encourage and not hamper the dried-milk
industry. ;

The commission desires to reaffirm the resolution adopted by the commission
at the Chicago meeting in 1918, regarding the favorable attitude to be taken
toward the manufacture and sale of dried or remade milk. It is recognized,
however, that all products will not be of the same grade and that grading will
be necessary.

In our judgment, the sanitary requirements to be adopted for dried and re-
made milk, as far aS applicable, should be the same as those for liquid milk of
like grade.

Milk powder which contains less than 25 per cent of its solids in the form of
milk fat should be labeled “skimmed” or “ partly skimmed.”

Milk powder which contains less than 38.per cent of fats in its solids should
be labeled “ skimmed.”

Those containing between 3 and 25 per cent of milk fat in their solids should
be labeled “ partly skimmed.”

The term ‘‘milk” should be denied to any product in which the milk fat has
been wholly or partly substituted by any other fat.

We shall have to defer other specific recommendations as to the grading of
dried milk, but recommend the study of grading. The following suggestions
are made as to labeling:

First, that the label show the quality of milk before it is dried, in terms of
our present grades and standards.

Second, that the label show the approximate time and temperature of heating.

Third, that if anything has been added to the milk in the process of manu-
facture or otherwise, its presence and the name and amount of the substance
added should be stated on the label.

Fourth, packages of dried milk should be labeled with the date of manu-
facture.

(14) Undernourishment in School Children.
RESOLUTIONS PASSED AT THE MEETING OF DEC. 8, 1918.

The commission has received from its members reports concerning
the prices paid for milk to the producer and the prices at which milk
is sold to the consumer, the quantity of milk sold, and the mortality
statistics from localities represented by members of the commission,
including Boston, New York, Philadelphia, Wilmington, Baltimore,
Toronto, Indianapolis, Chicago, Jacksonville, and others, and it is
the judgment of the commission—

(1) That the price of milk to the consumer from 1914 to 1918 has
in general increased from 50 to 100 per cent.

(2) That while the quantity of milk consumed has fluctuated in
the cities from which reports have been received, yet, generally, at the
present time it is not less than the normal or usual supply.

(3) That there has been an improvement in infant mortality and
a lessening in diarrheal diseases under 2 years of age and that this
improvement has not been checked by the advance in the price of
milk between 1914 and 1918.

24 COMMISSION ON MILK STANDARDS.

(4) That evidence presented to the commission indicates the se-
riousness of undernourishment or malnutrition among children of
school age. The commission believes that the cause of this is an
improperly regulated diet due to some extent to poverty and to a
larger extent to lack of appreciation of the value of milk as compared
with other foods.

(5) That the proportionate increase in the price of other foods
generally has been greater than the increase in the price of milk.

(6) That at present retail prices, milk is the most economical
animal food that can be purchased.

(7) The commission recognized that the results of nutrition investi-
gations during the past 10 years have demonstrated that satisfactory
nutrition is to be secured only through the employment of certain
combinations of foods. It recognizes that milk, eggs, and green
leafy vegetables are so constituted as to correct, when taken in liberal
amounts, the deficiencies, from the dietary standpoint, of cereal prod-
ucts, peas, beans, tubers, edible roots, and meats. Since good nutri-
tion can not be secured on diets from which milk, eggs, and the leafy
vegetables are absent, it is of the greatest importance that the use
of these classes of foods should be extended.

It is further recognized that among these, milk is the most effective
and most economical and that milk is the one food for which there
is no satisfactory substitute.

RESOLUTION PASSED AT THE MEETING OF MAY 21, 1920,

The commission, in connection with the school-lunch movement,
recommended that every effort be made to emphasize the importance
of good milk in the diet to promote its increased use in all systems
of school feeding.

(15) Clarification.

The process of the clarification of milk has come into such wide use
that the commission has felt it necessary to take cognizance of it, but
it does not believe that it should be recommended as a required stand-
ard method. In its favor are the following points:

(a) It removes visible dirt. ,

(b) 1t removes inflammatory products, including many of the causative
germs.

(c) It performs the work of the strainer, but in a much more efficient manner.

Against it are the following points:

(a) It removes visible dirt, but not all disease-producing germs, and hence
misleads the consumer as to the real purity of the milk.

(b) It does not remove urine or the soluble portions of feces; nevertheless
the milk appears clean,

COMMISSION ON MILK STANDARDS. 25

(d) It adds another process requiring handling of the milk, complicating the
situation.

(d) It largely destroys the value of the dirt test, though not more so than
good straining.

(e) It breaks up clumps of bacteria and distributes them through the milk.

(f) The exact nature of the material removed is not yet fully understood.

(16) Homogenization.

Concerning the subject of homogenized milk or cream. the commis-
sion bases its attitude on the principle of correct labeling. It is of
the opinion that in the compounding of milk or cream no fat other
than milk fat from the milk in process should be used, and that no
substance foreign to milk should be added to it.

The use of condensed milk or other materials for the thickening
of cream is opposed unless the facts are clearly set forth on the label
of the retail package.

Homogenized milk or cream should be marked as such, stating the
percentage of fat it contains.

(17) Licenses.

A milk dealer should be required to have a permit or license to sell
any grade or class of milk, and to use a label for such grade or class.
Such permit or license should be granted only after the local health
board has determined that the milk of the dealer actually belongs to
the grade, and it should be revoked and the use of the label forbidden
when it is determined that the milk is not in the grade or class desig-
nated.

(18) Score Cards for Dairy Farms.

RESOLUTION PASSED AT THE MEETING OF OCT. 15, 1917.

For the purpose of licensing and grading, scoring should be modi-
fied to include certain specific requirements for the various grades of
milk rather than a single arbitrary numerical score.

(19) Labeling.

All milk should be labeled and marked with the grade in which it
is to be sold. In dating milk, uniform methods should be adopted.
Besides the letter of the grade and the words “raw ” or “ pasteur-
ized,” there should be added sufficient statements to identify the
milk as to its source and the time at which it was produced, bottled,
or pasteurized; and no term descriptive of the quality of the milk
other than the officially adopted grades should be authorized, unless
such term is of a generally accepted meaning.

26 COMMISSION ON MILK STANDARDS. |

In dating milk, uniform methods should be adopted for all grades
of both raw milk and pasteurized milk, using the day of the week
or the day of the month.

The sale of milk which is mislabeled or misbranded should be pun-
ishable by revoking the dealer’s license, reducing the milk to a lower
grade, or by fines, or suitable penalties.

(20) Service Bureau.

RESOLUTIONS PASSED AT THE MEETING OF MAY 21, 1920.

The commission recommends the establishment of a service bureau
by the New York Milk Committee. This bureau should send a copy
of the commission’s reports to each governor, each State and provin-
cial health department, each State and provincial food bureau, each
mayor of cities of more than 10,000 inhabitants, and to each health
officer of such cities.

The bureau should offer its services In—

(a) The drawing of legislative measures relative to milk and milk
products.

(>) Furnishing literature and speakers to promote the adoption of
such legislation.

The service bureau should get track of agitation having milk legis-
lation in view throughout the country, through the services of clip-
ping bureaus, correspondence, and such other measures as are deemed
wise.

The service bureau should cooperate with the Surgeon General of
the United States Public Health Service and appropriate bureaus of
the Department of Agriculture, the Children’s Bureau, and other
agencies.

Resolved, That the service bureau write each State health and education
agency (boards of health, superintendents of education, etc.), suggesting that it
provide wall charts, slogans, pictures, ete., to hang in each school, setting forth
the need and advantage of a more abundant use of good milk as a food for
children and adults.

That in this letter there should be a suggestion that such pictures, diagrams,

charts, and slogans be developed in the schools of the State, through school and
individual competitions.

APPENDIX 1.—FACTORS OF PRIMARY IMPORTANCE IN DAIRY
PRACTICE FOR CONTROLLING THE SANITARY CHARACTER OF
MILK.

In its last report the commission placed in an appendix detailed
regulations for the control of sanitary conditions in dairies and milk
receiving stations.

The regulations given there have varying degrees of value in con-
trolling the character of milk. Many add expense to the cost of pro-

COMMISSION ON MILK STANDARDS. 27

duction, and some, while they improve external appearances in the
dairy, do not materially affect the quality of milk. The grading sys-
tem deals primarily with the character of the product, and the dairy-
man should give his special attention to such factors as will most
effectively improve the character of the product.

Hence, dairy inspectors should aim to place primary emphasis upon
the factors that most largely affect the quahty of the milk. The com-
mission urges all health officers and dairymen to separate the factors
of primary importance from those of secondary importance. The
following statements are not intended to replace more elaborate regu-
lations given elsewhere, but to show where the primary emphasis
should be laid and to distinguish the more important measures from
those that are of secondary importance in controlling the quality
of milk.

In what follows it is assumed that other standard regulations are
- adopted, and that no milk is to be shipped from cows evidently dis-
eased or with sore udders, or milk handled by employees sick with
any infectious disease or carriers of disease germs.

Where milk is to be sold in a raw state, it is assumed that all cows
will be under veterinary supervision and tuberculin tested once each
year, and dairy employees will be under regular medical inspection.

Under these condition it is the opinion of the commission that the
following factors are most essential in putting on the market milk
which is clean and contains a low bacterial count.

1. Financial Stimulus.

This factor underlies all others. Unless the dairyman can be con-
vinced that it is to his financial advantage to produce clean milk, any
attempt to purify the milk supply by legal statutes will be largely
futile. ‘To produce such a financial stimulus some form of grading
milk is necessary in which the public will have confidence as being
thoroughly reliable. This will involve:

1. (a) The health officer—The milk must be graded by the proper
authorities, and this grading should include constant bacteriological
examination of the milk furnished by each producer for the purpose
of grading.

(b) The dealer—The milk should be paid for by the.dealer ac-
cording to its grade. The most effective results will be obtained so
far as concerns cleanliness and sanitary character when the dealer
pays the producer for milk on a scale based upon its bacterial count
in addition to other factors.

The dealer should also thoroughly sterilize all milk containers by
steam before returning them for refilling. It has been found that
one of the greatest sources of trouble is the fact that the dealer re-

28 COMMISSION ON MILK STANDARDS.

\

turns to the producer cans which are not only not sterilized, but
sometimes not even washed clean. No producer can furnish good
milk in such cans, but the dairyman is almost sure to be blamed for a
condition for which the dealer is wholly responsible.

2. To produce milk of grade A or B, the producer will find the
following factors the most efficient in controlling its cleanliness and
its bacterial count:

(a) Milking—Cows should have clean udders. Hands of the milker should
be clean and dry. A small-topped milk pail should be used. With clean methods
no strainer is needed, but if one is used it is preferably of cloth (cheese cloth)
which has been sterilized by boiling. It is important that the same cloth shall
not be used for the morning’s milking and again for the night’s milking. Two
strainer cloths should be boiled, one used for the morning’s and the other for
the night’s milking.

(b) Sterilizing—All milk vessels should be washed with a brush and with
washing soda, or with alkaline powder and water, should be rinsed in clean
water and sterilized. Where steam is available, this should be used for steril- .
izing, either as a jet of live steam or under pressure. Where steam is not avail-
able an abundance of boiling water should be used.

(c) Cooling.—The milk should be cooled promptly to as low a temperature as
is feasible with facilities available. Where this is done in a water tank and
it is desired to stir the milk to facilitate the process, a wooden paddle of any
kind must not be used. A metal stirrer may be used, which must be thoroughly
washed and sterilized with boiling water each day. The lower the temperature
to which the milk can be cooled, the easier it will be to produce milk of low
bacterial count.

While other factors in milk production have their influence, ex-
tended tests show that 90 per cent of the high bacterial counts are
attributable to the neglect of the above.

The above sanitary measures have special reference to the preserva-
tion of the sanitary character of milk during the process of milk pro-
duction on the dairy farm. It is recognized that in addition to these,
precautions must be observed in the milk factory or shipping station
and on the railroad and in the city delivery station. In some cases
the chief trouble is after the milk has left the dairy. In shipment
three factors control the quality of the milk at its destination: Time,
temperature, and cleanliness of utensils. Thorough refrigeration of
milk in its progress from the dairy farm through the shipping sta-
tion, on the railroad, and in the city station is essential to prevent
large multiplication of bacteria. Washing and sterilizing of all ves-
sels in which milk is contained and of all apparatus with which it
comes in contact is vital if contaminations are to be prevented that
ean easily destroy the sanitary character of milk which may have
left the dairy farm in first-class condition. There is very little value
in the practice of sanitary measures by the dairy farmer if the milk
in the hands of the dealer is not properly refrigerated and handled in
a sanitary manner,

COMMISSION ON MILK STANDARDS. 29

Score Card for Ice-Cream Manufacturing Plants.

Perfect. | Allow.
BOCA LL OMaaceta state aiaiciala sles lajolele cea. esis, asiate nin is cece sees sisisisinwins scence ces asec scgsecece 15
PAM OVORSL OUI cresoe isa etsicioie ds sisi cine sloreicie,c Static, Siareialcicin ste cisiie melas sca sie sia eaiians 5
Free from contaminating surroundings (no score if bad)..............----.--- 3
ibrotectednromistreet Gust sma. ccccescsecs aacene ee selec eee tb eeu eae escconee cane 3
INOt connected withyany other TooMm cc. s hos so.ecne aac ee niees cee se eisss cee 2
Nother; business:in'sameiestablishments4- --2.+s-cec-oct aecee ces eee aeee ae 2 |
GON GENUICHI ONE oe a Seelss aictelaa ee howe See lne omega eis ccm ainhiscscedes cites cose 15
web ptivedn(na tinal) ei So4ses eee eee ioe cee mace ee eee eis Hotei 2
Wielinvenitilatedinn soe sce c tote eee esis ae hieie un See ees de aieeew cla nemesis 1
PRNOOUGHIVASCrCELL OGM ee cites snicicices neiaciodaieie cis s ciniciciet ciate baste seiner sialeciosie sin 2
Water-closet does not open directly into establishment ...............-------- 2
Separateroom forswashing.utensilss2o 52... 6 oo scc a. cane cree ctecsesccect tenes 2
oor Smooth, water-tightt wellidrained ia: Sohcce.-osccect ose soscie a eons as se 4
Wiallstandicelling:; Smootland tent tos .). cs ae eine sniscle ala cle = se io oyelsic,- nieis.'ssie 2
HICH TAL TOTTI GLUT eee eee tee ert ee es re cadets mann tk enor ee eect cee ceanee 30
Steam atrallitimeslteee ce aes ee wesc mee nise meinen cletcsaa es coaricne cae cts sane i
Hot water at all times (no credit unless running hot water) ....-.......-.-.---- 3
SLELIUZEMMOMU LOL SUS Hopes Saale icles ca sistant slelejsiioie Ges Sociebicincmm aes asecisee tale 3
Connections for sterilizing apparatus.....-..-.--..-.-.-------- SeteNecc bint vase 2
Pasteurizer:
EVOIGING] MACHINE Me verersaels eetetleeesiecisine sia mei clei ide Rie Se oceieisicGie's craters amici
Automatic recording device...........-- sare
Refrigeration: Mechanical (proper ice box, 1)
Freezer: Type, connections, etc.........-...-
SANA NOME ok dooaab sone cuCO EOS ESOL oe Sc0 GSU a crn ME Con uOnesOene mace :
Washbasinsjand'towelsiampletos.2c ccs nec ger -fecciee cae aichiseseser ess scleaiee sae
Utensils:
(COMATEL OMAR Ree eee cate ates rae Ce ason a nines See cab ane cae eee nteaee i
Ample forthe SOrvice a). as ecsccc gcse eae es ce Je cee seer SERRE epee 1
RACKSHOR Sete ce oe ale oslo dc oistassatamie misjornee ae alee echoes cease cele Me ee eieiseicce 1
Employees:
aslthicertiticatesifones on) ac cone a et sock cesace te echo conde sereees 1
@legnisiits*provided te. + 7.2825. oes cae ea-catanatecd= ns daccicecls cc 1
[IG ALIS) 2 Soe GES RE COCO OSCE HE EOE SORE EA Henan einise Ia geen Reale eee ene 40
reed OM rOmUfliGsmacesswa tals cosicie = Saale © s cinaneselsge sealed Siege Satcicese tes 2
Protection of material:
Before mMaNulachures. 42 sas cisten ocicise nee ceases mee ote ecteseces accesses 3
Duin MAN WAChUTe = -s naa. scene cae soces cies e clemae see aicaicisnie cerns nocintc 3
VATE ATH AGITITE Mies te sac ccociciesine cceicine cose Sa ccigee ses soncmeteocebee sss 3
Utensils and apparatus sterilized (washed in hot water, 1)......-.-.--.------ 3
Cleanliness:
ROOTS ery ee sare rs era Score a ara eis site ara ws eins els aac clelats coaisaite 3
IV LING OWS ee ere icteric totes eeteic nnle aes ctn Oe Datidaailssce im aimins dae he Sen cinecie 1
ae SAT EELS sche ose ates cata arse aoe Oe citer ab rercicte dtiecbels cimieatoeaplattealate 3
eis(am diceilia oer tometer Wa ae eh eons na RecN Nascbet hace eeeles 1
LORS Ree Re eet aS SO DE CEES SMe Bereta Sorin See eRe Rapier 3

Employees. .....-.
Character of materials used:
Milk and cream, grade A (grade B, 4; grade C, 1)

Condensed milk, eggs; ete so. ces t se ceclua tee e-cdscsceec ese

Thickeners MONE WISER <2 | a1) taser acicicistmee Ss ccisccscineineaipetes ae

AT INCLAL COLOTIO Py LOMOE -minsiccise ceisicinctonsiecinea ce cmecis nas smee sees sect caters
Degresiofrefrigeration of finaliproduct. . <2). .ca2-6 2 ss-sc0et ec -<ne's- ++ esses <=

EU OD eae ee eh as mates clare Helse HMMS ol haials tease nalainy Schice sami seit aaa seers 100

30

JEMPERATURE FAHRENHEIT

COMMISSION ON MILK STANDARDS.

TimME ANO TEMPERATURE FOR
MILK PAST EURIZATION

TIME 1N MINUTES

COMMISSION ON MILK STANDARDS, 3l

APPENDIX 2.—HISTORY OF THE COMMISSION ON MILK STAND-
ARDS APPOINTED BY THE NEW YORK MILK COMMITTEE.

Milk Grading Previous to the Commission’s Organization.

In 1907 there was held a milk conference in Washington called by
the commissioners of the District of Columbia to report upon the
milk supply of that city. At this conference Dr. A. D. Melvin offered
a resolution proposing that milk be classified into three classes:

Class 1, certified milk; class 2, inspected milk; class 8, pasteurized milk.

In the first two classes the cows were to be tuberculin tested and the
milk was to have bacterial standards. The conference recommended
this classification. The proposal was notable because it provided for
the pasteurization of all milk, with the exception of milk from tuber-
culin-tested cows, produced under sanitary conditions.

In 1908 the Board of Health of New York City adopted a classi-
fication of milk as follows:

Class 1, milk (ordinary market milk, raw or pasteurized) ; class 2, selected
milk; class 3, inspected milk; class 4, guaranteed milk; class 5, certitied milk.

Class 1 represented the bulk of the supply, and no provision was
made requiring either pasteurization or a bacterial standard.

Organization of the Commission on Milk Standards.

In 1910, December 2 and 3, the New York Milk Committee held a
conference of leading milk authorities in America, on milk problems,
at which the following resolution was adopted:

Resolved, That pending the adoption of national standards the conference
on milk problems of the New York Milk Committee indorse the classification
of milk recommended by A. D. Melvin, Chief of the Bureau of Animal Industry
of the United States Department of Agriculture, approved by the milk con-
ference of the District of Columbia, 1907, and published in Circular 114 of the
Bureau of Animal Industry, and in Bulletins Nos. 41 and 56 of the United States
Public Health and Marine Hospital Service.

(This classification designates three kinds of milk—certified; in-
spected ; pasteurized. )
This same conference also passed the following resolution :

Whereas it has been demonstrated by the papers and the discussions at this
conference, held at the invitation of the New York Milk Committee, that it is
imperative that definite standards and regulations should be adopted to govern
the production and handling of dairy products for the prevention of disease
and the saving of lives.

Resolved, That the New York Milk Committee be requested to invite between
12 and 20 recognized experts on milk problems to meet in conference, and that
those experts be asked to make a unanimous report, recommending proper milk
standards on which Congress or State authorities may formulate milk legisla-
tion. ;

32 COMMISSION ON MILK STANDARDS.

In accordance with this resolution, in March, 1911, the New York
Milk Committee, which is a voluntary organization working for the
improvement of the milk supply of New York City and the reduc-
tion of infant mortality, invited 20 experts to become members of a
commission on milk standards. These men were selected from a list
of more than 200 men of prominence in medicine, sanitation, public
health, and laboratory work, who were recognized as authorities on
the milk question.

The members at the present time are as follows:

Dr. Carl L. Alsberg, Chief Bureau of Chemistry, United States Department of
Agriculture, Washington, D. C.

Dr. John F. Anderson, of E. R. Squibb & Sons, New Brunswick, N. J.

Dr. B. L. Arms, State bacteriologist, Montgomery, Ala.

Dr. W. A. Evans, department of preventive medicine, Northwestern University,
Chicago, Ill.

Dr. Charles J. Hastings, medical officer of health, Toronto, Canada.

Dr. J. N. Hurty, secretary State board of health, Indianapolis, Ind.

Dr. E. C. Levy, health officer, Richmond, Va.

Prof. E. V. McCollum, School of Hygiene and Public Health, Johns Hopkins
University, Baltimore, Md. :

Dr. J. R. Mohler, Chief Bureau of Animal Industry, United States Department
of Agriculture, Washington, D. C.

Dr. J. S: Neff, Narbeth, Pa.

Dr. Charles KE. North, 30 Church Street, New York City.

Dr. William H. Park, director of laboratories, department of health, New York
City.

Mr. R. A. Pearson, president College of Agriculture, Ames, Iowa.

Dr. M. P. Ravenel, department of preventive medicine, University of Mis-
souri, Columbia, Mo.

Prof. M. J. Rosenau, department of preventive medicine and hygiene, Har-
vard University, Cambridge, Mass.

Prof. H. C. Sherman, department of chemistry, Columbia University, New
York City.

Dr. L. L. Van Slyke, agricultural experiment station, Geneva, N. Y.

Mr. C. H. Wells, health officer, Montclair, N. J.

Dr. William C. Woodward, health officer, Washington, D. C.

In the list of names above there are seven public health officers, six
bacteriologists, four chemists, and two agricultural experts. Four-
teen out of the number have been educated as physicians; three of
the members have had long practical experience in the milk industry;
six have been connected with the production and control of certified
milk.

Purposes.

While this commission was created by and its expense is borne by
the New York milk committee, it has not been the intention of the
committee that the commission should have the New York City milk
problem solely in mind. It was desired that the commission should
make recommendations regarding milk standards and legislation that
might be adopted by any city or town in the United States or Canada.

COMMISSION ON MILK STANDARDS, 33

Meetings.

The first meeting of the commission was held at the New York
Academy of Medicine on May 22, 1911. The subjects discussed
included bacterial standards, chemical standards, and the grading and
classification of milk. Several committees were appointed to report
at the next meeting.

The second meeting of the commission was held at the New York
Academy of Medicine, October 5 and 6, 1911, at which the reports
of standing committees were received and resolutions adopted con-
cerning bacterial standards, chemical standards, and grades and
classes of milk. Special committees were appointed to consider cer-
tain specific matters. The commission tentatively recommended that
milk should be classified as follows: Certified; inspected; market ;
cooking; that there be bacterial standards; and that the last two
classes should be pasteurized.

January 4, 1912, the New York City department of health made
an amendment to its sanitary code providing for a new classification
of milk, as follows:

Grade A, for infants and children, including: Certified, guaranteed, inspected
(raw), selected (pasteurized) ; grade B, for adults, including: Selected (raw),
pasteurized ; grade C, for cooking, including both raw and pasteurized.

It is noteworthy that this grading system made some use of the
recommendations of the Commission on Milk Standards, but omitted
any bacterial standards for grade B or grade C milk, and permitted
the sale of raw, unpasteurized milk in all grades. At the same time
it was recognized that this action of New York City was a great step
in advance, and an indication that the commission’s work gave
promise of taking practical form.

First Report.

The third meeting of the commission was held at Homer, N. Y.,
January 25, and at the New York Academy of Medicine, January 26
and 27, 1912. At this meeting minor matters were voted upon and
preparations made for the publication of a report of all of the com-
mission’s work. The first report appeared in the Public Health Re-
ports of the United States Public Health Service, volume 27, No. 19,
May 10, 1912; 70,000 copies of this report were distributed.

The fourth meeting of the commission was held in Chicago, Octo-
ber 29 and 30, 1912, at the time of the National Dairy Show. At this
meeting the commission attended the annual convention of the Inter-
national Milk Dealers’ Association, and took part in a discussion of
the classification of milk and milk standards with the leading repre-
sentatives of the milk industry of the United States and Canada.

The fifth meeting of the commission was held in Richmond, Va., on
May 2 and 3, 1913. By this time the commission had the benefit of

34 COMMISSION ON MILK STANDARDS.

numerous criticisms and suggestions which had been called forth by
the first provisional report. At this meeting the commission made
some radical modifications of its standards and grades, as follows:

(1) That in classifying milk the grades be designated by letters only, and not
by such words as “ certified,” ‘‘ inspected,” ‘‘ selected,” etc.

(2) That the classification be changed to include only three grades:

Grade A, consisting of two classes, raw milk with a bacterial standard of
100,000 per ec. ¢., from tuberculin-tested cows (employees medically inspected) ;
pasteurized milk with a bacterial standard of 100,000 per c. ce. before pasteuriza-
tion and 10,000 per c. c. after pasteurization.

Grade B, consisting of one class, with a bacterial standard of 1,000,000 before
pasteurization and 50,000 after pasteurization.

Grade C, consisting of one class, over 1,000,000 before pasteurization and
50,000 after pasteurization.

Second Report.

The second report of the Commission on Milk Standards was pub-
lished by the United States Public Health Service in the Public
Health Reports of August 22, 1913, and contained the new grading
system as above recommended. This report was indorsed by the
American Public Health Association at its annual meeting at Colo-
rado Springs, September 9-13, 1913.

(January 1, 1914, the New York City Department of Health
amended their grading system so as to conform in its essential fea-
tures to the new grading system recommended by the Commission on
Milk Standards. This was soon followed by action by the New York
State Department of Health in establishing a grading system for
all towns and cities in the State. Later on, the cities of Newark,
N. J., Jersey City, N. J., Richmond, Va., Kansas City, Mo., adopted
similar though not identical grading systems. The grading of milk
is also being considered at the present time by the public health
authorities of several other municipalities as well as States.)

The sixth meeting of the commission was held at the New York
Academy of Medicine, April 13,1914. At this time special attention
was given to milk products and reports presented by the members
of their own investigations on the sanitary and bacterial conditions
of the ice cream and butter in various parts of the United States and
Canada.

The seventh meeting of the commission was held in the Hotel Bilt-
more and the New York Academy of Medicine, May 7 and 8, 1915.
On this occasion the commission met the officers of a number of
commercial organizations, including the National Ice Cream Dealers’
Association, the National Creamery and Butter Makers’ Association,
and the International Milk Dealers’ Association. The deliberations
dealt chiefly with the subjects of butter, ice cream, and other milk
products and also with the questions of the control of certified milk
and dairy inspection.

COMMISSION ON MILK STANDARDS. 85

A special committee of the commission met in Washington on Janu-
ary 17, 1916, with the Joint Committee on Definitions and Standards
appointed by the Bureau of Chemistry of the United States De-
partment of Agriculture. The object of this meeting was to permit
the members of the Commission on Milk Standards to present to the
joint committee the results of the work of the Commission on Milk
Standards and to urge the Joint Committee on Definitions and Stand-
ards, which represents the food and dairy commissioners of the
various States, the agricultural chemists, and the United States De-
partment of Agriculture, to approve of the adoption of uniform milk
standards for all of the States and of the bacterial testing and grad-
ing of milk according to its sanitary character.

The eighth meeting was held May 19 and 20, 1916, in the New
York Academy of Medicine. This meeting was especially effective
because of the extensive work performed by the standing committees
of the commission, which held their own independent meetings in
various parts of the United States several weeks in advance of the
general meeting. As a consequence of this preparatory work each
committee brought in most complete and extensive reports of the
subjects with which they had to deal. These subjects included ice
cream, butter, condensed milk, standards for small communities, the
significance of bacterial counts, essentials of dairy scoring, adjusted
milk, clarification, pasteurization, tuberculin testing, and other minor
matters. This present report is a summary of the conclusions reached
by the commission as a result of all of the sessions, and may be re-
garded as superseding the previous reports.

The ninth meeting was held October 15, 1917, at the Congress
Hall Hotel, Washington, D. C. Action was taken recommending
to the Federal Food Administrator, Herbert C. Hoover, that he have
maintained an adequate supply of cows’ milk of proper quality and
at a reasonable price for maternity and infant feeding. It was pro-
posed that governmental or other aid be provided for this purpose.

The tenth meeting was held December 8, 1918, at Chicago, Ll.
At this time the commission considered the existence of under-
nourishment in children; the importance of milk because of the
protective substances it contains; the bacterial testing of milk; and
the use of powdered milk and other products in the production of
recombined or reconstituted milks.

The eleventh meeting was held May 20 and 21, 1920, at the New
York Academy of Medicine. The principal subjects considered at
this meeting were: Time and temperature of pasteurization ; infected
udders; milk for school lunches; dried milks; and a service bureau.

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