The Problem Of Food Control
( Originally Published 1939 )
Changes in sources of food supplies. When population was smaller and less concentrated in great urban communities, the food supply was produced in the immediately surrounding country. Many households raised a large part of their food in their own gardens; and the remain-der was, for the most part, furnished by neighboring producers. These supplies were delivered and served fresh. The different foodstuffs were packaged and marketed by the man who originally produced them, and the consumer knew the source of the food that he was buying. If a given product was unclean or poor in quality, this was largely a matter between the vendor and the immediate consumer. The food might be adulterated (as by the addition of water to milk) or harm-fully contaminated (as in food production under unclean conditions) or pathogenically infected (as in handling by a typhoid case), but these possibilities were not generally recognized.
When population increased, and small towns grew to be great cities, it became impossible to supply enough food from the immediately surrounding countryside. The increased price of land, the development of specialized industries, and the growing disinclination and inability of consumers to raise their own food supply all contributed to an in-creasing demand for food that could be purchased. Such food had to come from greater and greater distances. The development of railroad and steamship systems, followed later by that of refrigerated service in transportation, storage, and delivery, made the products of remote farming districts available to the population at large. In addition, these developments made available a greater variety of food. Sub-tropical fruits and vegetables, as well as off-season products, became purchasable at almost all seasons of the year in most of the large population centers. New sources of food are still being opened up, and new varieties are being secured by the improvement in highways and automotive transportation, and by food technological research. For example, carlot shipments of certain fresh vegetables increased from about 82,000 in 1920 to more than 201,000 in 1930, whereas the shipments of potatoes increased from 185,000 to only 252,000.
Commercialization of food production and handling. Such developments could not have been realized without the investment of large sums of money in equipment, plant, research, invention, and personnel. Capital was attracted by the expectation of profitable returns. This has led to the commercialization of the food industry. The identity of the producer and the source of a given product are lost in the bulking of huge shipments. The food is transported in tank cars or refrigerated trucks or in whole trains. It is stored in great cold-storage warehouses. It is processed in large plants where the latest applications of engineering afford economical handling and uniform quality.
Any part of a shipment that becomes contaminated may damage the whole. The sale and distribution of such foods may cause wide-spread illness; and if this illness is traced to a food plant, the business is seriously affected. Many customers are lost, public good will is jeopardized, prestige is weakened, and the money previously spent for advertising and promotion will have been wasted. In addition, the business may be closed by the public authorities. Therefore, if for no other reason than insurance against loss of trade, the large food-processing companies are able and, in most cases, quick to apply the latest discoveries in control of food quality.
Health hazards in food. Microbes which may be disease-producing or deleterious to quality gain access to foodstuffs in several ways. They may infect the raw product at the source of production as, for example, pathogenic bacteria in milk, oysters, and meat. They may find lodgment on food during its production, transportation, and handling, by air currents or by contact with infected surfaces, implements, containers, or storage bins, as, for example, spoilage microorganisms on fruit and in milk. They may be introduced during the manufacturing operations as, for example, by direct contamination from an infected workman or by infestation of the plant with flies, dirt, or vermin. The mixed flora of bacteria, yeasts, and molds which infect almost all natural products may spoil them, when the processor neglects proper care in their handling. Sometimes the addition of chemicals to protect the food from decomposition by microorganisms renders the food harmful to health, as in the case of poisonous insecticides and preservatives. Moreover, the pressure of competition induces some manufacturers to resort to fraudulent practices to cheapen their products or to give them fictitious values.
Types of violations of food-control laws. The consumer under-stands that a "pure" food is one that has not been changed from what experience has taught him to expect as to its wholesomeness, safety, palatability, and nutritive quality. Scientific and legal considerations distinguish between types of harmful and fraudulent mishandling of foods as follows:
Infection: the presence of undesirable, viable microorganisms which have entered into the food from some source during production or handling, and proliferate to spoil the food or make it dangerous to health, e.g., typhoid bacteria in oysters.
Contamination: the presence of any undesirable substance, organic or inorganic, viable or inert, which is foreign to natural food, e.g., dirt on bread.
Adulteration: the addition of a substance which reduces or lowers the quality or strength, e.g., water in milk; or the substitution of one product for another, e.g., coconut oil for butterfat; or the abstraction of any valuable constituent, e.g., leaching of soluble nutrients by the floating of oysters; or the addition of colors or other substances to conceal inferiority, e.g., yellow dye in plain noodles to simulate the presence of eggs; or the addition of poisonous substances, e.g., insecticide sprays on food; for the presence of any portion that is filthy, putrid, or decomposed, e.g., spoiled tomatoes in ketchup.
Misbranding: the labeling of a product to be what it is not in identification, quality, or amount, e.g., milk bread which contains no milk or which is false in its claim of weight.
Sophistication: fraudulent treatment of a foodstuff to conceal its poor marketability, e.g., cleaning and polishing of moldy fruit to simulate freshness.
Food inspection. The intricacy of the food-processing operations, the multiplicity of the human contacts involved, and the large scale of the operations, with their attendant communal health hazards, have led society to endeavor to protect itself by instituting public-health supervision of food production and handling. The public themselves have not the time or the specialized knowledge to give satisfactory supervision. They have demanded and then provided official inspection of food products in order to insure a safe, wholesome, and clean food supply.
Unfortunately, food inspectors have often been appointed to discharge political debts, with little regard as to their actual ability to inspect and safely control a food supply. However, such conditions are slowly being remedied here and there through civil service whereby appointments are made on the basis of demonstrated qualifications, through the inauguration of courses of instruction by progressive regulatory control officials, and through the increasing public interest. As a group, they are honest and conscientious, and many are well-trained food sanitarians of high professional attainments.
Former emphasis. The very nature of the problem which has led to the inauguration of food inspection placed the emphasis upon ferreting out food adulteration, misbranding, spoilage, and unwholesomeness, and then upon apprehending the guilty vendor and penalizing him as a punishment for the past and a deterrent for the future. The inspector was really a trained policeman on special duty. He had to deal with vendors many of whom were ignorant, some unscrupulous, and a few vicious. He did not have much scientific knowledge to support his work. Most of his legal cases were handled in police courts where a practical kind of crude justice was administered. He had to bear rough treatment, utilize whatever information the laboratory could supply him, try to win his cases, rise above discouragement, and, at the same time, maintain his integrity and ideals.
In the commercial field, the producers and the plant men had not been educated to the newer public demand for sanitation and quality in the food supply. They had been so accustomed to the commercial emphasis on cheap buying, economical plant operation, advantageous selling, and sales promotion that they often failed to realize that the products they handled were human food. Commercial expediency was thought to be incompatible with due regard to safety and esthetic considerations. As far as official inspectors were concerned, the plant men considered them busybodies or worse. Often the objective was no higher than to make the final product attractive only in appearance. Many operators were negligent of proper cleanliness and other practices of good housekeeping.
Present emphasis. As the public has become more vocal and discriminatory in its demand for a safe and wholesome food supply, and as a new generation of food handlers has arisen, there has gradually developed a change in the inspector-dealer-consumer relationship. The inspector usually finds the dealer to be as intelligent and well-meaning as he himself is, and vice versa. The official inspection force is recognizing that commercial interests have not only specialized knowledge but also a sense of their social responsibility. Increasingly, health officials are organizing advisory committees from the food industry to assist in drawing up regulations, establishing standards, and developing needed equipment. Likewise, commercial men seek the advice of control officials on various aspects of business, such as types of equipment to buy, needed legislation, improved public relations, and kindred subjects. This increasing collaboration has redounded to the improvement in the public health and the elevation of the food industry to a high plane of quality production and economical operation.
There is still a tendency for some food-control officials to feel a superiority to the commercial interests in knowledge and ideals. Many are inclined to follow bureaucratic patterns of self-perpetuation by a continual increase in regulatory requirements. These often go far beyond the exigencies of public-health value. Examples of this tendency are meticulous equipment specifications, ultra refinements of grading standards, and conflicting or contradictory sanitary requirements for milk in neighboring communities.
The commercial interests sometimes oppose public-health legislation which they consider to be inimical to business. Even discussion of technical and sanitary problems within the industry is often tempered by fear of stimulating regulatory action.
Public-health objective. The original incentive for the inauguration of food control was the recognition that many cases of illness and death were being caused by the consumption of impure food. Regulatory efforts were aimed to protect food from being infected with pathogenic organisms, from being preserved, colored, flavored, or contaminated with harmful chemicals, from containing filthy, infected, or decomposed parts, from miscellaneous adulteration and sophistication, and from sale under false labeling or misbranding. We still recognize the need for protecting food from such abuse. Standards of plant performance and quality of products must be formulated to guide supervision, and to prevent confusion and misunderstanding. The channels of trade in food must be systematically policed, samples collected for analysis, and infractions of the law corrected, preferably by the helpful collaboration of officials and producers, or by fearless prosecution if necessary. The same principles obtain in commercial quality supervision: all food processing must be standardized and con-trolled, and the irregularities that invariably occur in operations and in the quality of products must be followed up to learn the cause. This knowledge makes it possible to institute correction in the plant performance, and to minimize the likelihood of a repetition. The obligation to supervise and produce food that does not entail a health hazard rests equally strongly on both the official and the commercial interests. Many court decisions have supported this doctrine.
But more than this is involved. The researches in nutrition within the past twenty years have brought to light an entirely new phase of the relation of food to health (see discussion in Chapter III). As Sebrell points out, we are seeing a new field of preventive medicine open before us as the attitude of the health officer changes from one of simply defending his community against infectious diseases, to one of building a strong and healthy population with the highest resistance to disease. Such a program must improve personal efficiency and strengthen the productive capacity (and wealth) of the community. The people must be taught to look to the health department for authoritative information on the prevention of dietary diseases, just as they have been taught to look to it for authoritative information on the prevention of infectious diseases. Adequate and satisfactory nutrition is the foundation on which the public health must rest. All the factors contributing to such a desideratum have passed the experimental stage. The facts await their application on a community scale.
Control measures. The great advances in the improvement of the sanitary quality of food have been coincident with and were largely caused by the enactment of federal, state, and municipal laws, ordinances, and regulations establishing quality standards and prescribing sanitary practices. These enactments exerted salutary effects on three fronts. In the first place, they set standards of food quality, so that, by authorizing the inspection staff to enforce them, they secured compulsory compliance. In the second place, they aroused the public to the significance of the relation of impure food to disease, and developed support for the enforcement program. Finally, they operated to improve food quality so markedly that food consumption has increased and the food industry has prospered.
The industry as a whole has responded to this endeavor. Some firms have always been active in producing a high-quality line, but the great majority were motivated by the demands of the situation, namely, official requirement and public preference. Many firms are now capitalizing on this sanitary-mindedness of the public and are featuring the relative superiority of their products.
In recent years, food-control officials have placed an increased emphasis on the prevention of illegal practices at the manufacturing sources rather than merely policing the channels of trade to apprehend violators. The officials have freely counseled with inquirers as to whether a given practice is illegal, or whether the control officials will take action against the practice—a distinction with a real and practical difference. Moreover, the establishment of advisory committees and other educational and collaborative programs between the control and the commercial groups has enabled the latter to understand official purposes and policies, and to conduct their businesses in the light of this knowledge. Also, there is the establishment of official inspection services for whole industries whereby proper packing conditions are insured at the production and manufacturing centers.
These preventive measures are the highest form of effective food control because they reduce administrative expense for prosecution and clean up a whole industry by preventing the scattering of illegal food which later can be found only in small lots, if at all. At the same time, it educates the food-handler as to the desirable and the legal procedure; and he usually responds, because the average man wants to do the right thing, and especially because most of them find that it pays.
No law-enforcement program can succeed unless it has the support of the people concerned. Enforcement of food control either by regulatory officials or by commercial interests is ineffective to the extent that the public does not understand or support their efforts.
Education. Sherman points out that a discovery in sanitation may be made effective by a public-health regulation without any member of the community knowing anything about it, whereas a discovery in nutrition must be applied by the individuals themselves. Each person must know what to eat and why. He must be made to realize that his personal welfare is largely determined by what and how he eats. He must know that the problem is not solved when pure and adequately nutrient food is delivered to the home: it must be kept free from unwholesomeness. The consumer must know how to keep it to prevent spoilage, and how to prepare it for the table so as to conserve its nutrient values. The only road to this goal is education. An earlier and prolonged prime of life, a lengthened maintenance of the characteristics of youth, and a longer lease of life are desiderata the means of attaining which the public should know for the direct effect on their own lives as well as for the indirect effect on the public health. A stronger, more robust, more efficient, more intelligent, and healthier population would certainly be a happier and a more prosperous one.
The food official has the specialized knowledge and the ear of the public. The opportunity is at hand to extend and apply "the newer knowledge of nutrition." At the same time, the commercial man has a responsibility to confine his publicity and promotion program to matters of truth.
The food official knows the technical and most of the economic problems of the food industry. He works with the producers and manufacturers, with the growers and the dealers. He knows the public need, and largely the public mind. He is also in a strategic position to help these groups understand one another. Such harmony makes for better food, for friendly producer-dealer-public relationships, a healthier public, and a more prosperous industry.
Another development in the educational program of the health officer is the inauguration of special training courses for his staffs of laboratory and field workers. The rapid advances that are being made in food technology and laboratory methods require constant study to keep abreast of the new developments. The inspector is weak to the extent that he does not know more about his subject than do the people whom he supervises. Special schools or courses of instruction are being instituted in many of the health departments, both state and municipal, often assisted by the U. S. Public Health Service.' Several colleges have recently established regular courses in. food technology, both undergraduate and graduate, and the number is increasing.
Results of food control. In order properly to appraise the effectiveness of current practices in food control and to justify their cost, it is enlightening to review briefly the situation in the commerce of food products in the days before official food control had been instituted. When Dr. Wiley and his associates were endeavoring to arouse the country to the need for federal legislation in the interest of pure foods and drugs, food adulteration was very prevalent. Wedderburn states that the character of the adulteration generally was harmless, except from the financial standpoint, although there were many cases where ill health and even death followed the use of articles "poisoned with pigments, acids, tin, rancid oils and other injurious commodities which are used to cheapen and add beauty to the article sold. Polishing, powdering, watering, and adding such ingredients as earth, cracker-dust, peas, beans, starch, etc., are comparatively harmless and would pass for honesty and uprightness when compared to . plaster of Paris, soap stone, fusel oil, red ocher, fuller's earth, terra alba, and other ingredients of like character . . ." 5 It was estimated that at least 15 percent of the food products were adulterated in one form or another, and the overwhelming proportion of these was sold under fraudulent brands. In order to show the salutary effects which would follow the enactment and enforcement of effective food and drug measures, it is stated that in 1884 the state of Massachusetts found over 60 percent of collected samples to be adulterated, whereas, in 1886, the adulteration had dropped to 36.9 percent.
Since the enactment and enforcement of the food-control laws, there has been a noticeable change in the kind of violations. Gross adulteration and obvious misbranding have become less prevalent.
More subtle forms of adulteration have been appearing. The in-creased utilization of technical information in the food industry has prevented the perpetration of many of the grosser, unintentional violations, and when deliberate fraud has been encountered, it has been technically refined. Even in the year 1937 it was estimated that enough adulteration by the addition of water to food was prevented to make this phase of law enforcement alone save the consumer many times the total amount of money appropriated for the enforcement of the statute.'
The Federal Food and Drugs Act of 1906 had its limitations in that its provisions were not broad enough to cover many glaring needs for control in the food and drug industries, and this was pointed out by the U. S. Food and Drug Administration as far back as 1917.8 The act lacked legal standards for foods, contained no authority to inspect warehouses, could not control fraudulent statements about foods in general advertising (except those, on the labels), and was weak in many other respects. In 1933, the late Senator Royal S. Copeland, formerly Commissioner of Health of New York City, introduced a bill in Congress preserving all the many worthy features of the statute and correcting many of its weaknesses. After some revision, Senator Copeland's bill was finally approved on June 25, 1938, and its general provisions became effective one year from that date. The original bill also contained provisions which sought to prevent false advertising, including those in newspapers and radio broadcasts, but these have been comprised in a separate act (approved March 21, 1938), which will be enforced by the Federal Trade Commission (see Chapter IV).
The public has been educated to the relation of food to the public health. The press, civic organizations, and law-making bodies quite generally support pure-food legislation and its impartial, effective enforcement. This is evidenced by the changed appearance of restaurants and the type of service—the sanitary appearance of the front of the establishment indicates what the proprietor thinks will appeal to the public. The enormous increase in the sale of packaged food reflects the new emphasis on the packer's responsibility and the consumer's preference for sanitation in food handling.
More and more the public is demanding wholesomeness and nutritive value in food and truthfulness in its advertising. Even the avidity with which many persons chase after food fads bespeaks their interest in the problem of proper nutrition. Much of the awakened food-mindedness is the result of the educational emphasis on the newer knowledge of nutrition; a great deal is credited to the work of the enforcement officials and school authorities; and some must be credited to commercial food advertisements of the better kind.
All these forces of food control and of public demand have exerted a measurable effect on the public health. Food-borne disease has de-creased enormously. Its measurement is impossible for foodstuffs in general because of the difficulty of definite diagnosis as well as the generally non-reportable status of food-borne outbreaks. However, milk-borne disease has markedly decreased, as indicated to a large degree. by the statistical decline in infant mortality. This is not altogether attributable to the improvement in the quality of the milk supply, yet all authorities recognize its very great influence. Milk-borne epidemics have practically disappeared from communities which have well-organized health departments. Canned products are now among the safest foods the public can buy. Much of this improvement has been accomplished by the removal from the market and the destruction of food of questionable wholesomeness; much is due to the enlightenment of dealer and consumer; but probably the greatest influence is the faithful policing of the distribution channels. The very presence and inspection procedure of regulatory agents (official and private) constitute a salutary force for maintaining proper production procedure, thereby preventing trouble at the source. Such prophylaxis in food handling is an important public-health accomplishment.
1. Final Report of Mixed Committee of the League of Nations, Geneva, 1937.
2. W. H. SEBRELL, J. Am. Dietet. Assoc., 13, 305 (1937).
3. Report of the Food, Drug, and Insecticide Administration, U. S. Dept. Agr., 1928.
4. C. E. WALLER, J. Milk Tech., 1 (3) 16 (1938) ; F. ELY, ibid., 1 (4) 43 (1938).
5. A. J. WEDDERBURN, Div. of Chem., U. S. Dept. Agr. But. 32, 1892.
6. Report of the Chief of the Food and Drug Administration, U. S. Dept. Agr.,
7. Ibid., 1937.
8. Ibid., 1933.