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A CONSIDERATION OF THSZ FACTORS OF A CITY WILK ORDINANCE.

by

~~

J. CARLTON HURLEY
>

1913

SUBMITTED AS A THESIS FOR THE DEGRES M. 8.
A Consideration of the Factors of a City Milk Ordinance

It has been truly said, if not artistically expressed, that
“the milk problem in America today is perhaps the toughest of all
of our pure food and public health problems.* It is one which con-
cerns every human being. It has furnished abundant material for
periodicals in the way of cartoons and popular reading. Usually
such articles claim to contain the solution to the entire problem
but in most cases the writer has grasped but one strand in a com-
plicated and extensive system. In most cases such writers oan be
forgiven their conceited efforts to proclaim their solution of
the problem. Any one phase of the question is so far reaching and
extensive ae to successfully prevent any one individual from graep-
ing the problem in its entirety.

In the "Survey" in 1910 appeared an article dealing with the
milk question entitled "Put the responsibility on the right shoul-
ders." It was very brief but was a surprise in that it did not
place the responsibility on the shoulders on which it is popularly
supposed to rest. The writer was one of the adwance guard on the
milk question and had discovered that the responsibility rested
only to a slight extent upon the shoulders of the farmer but quite
heavily on those of the consumer. The health departments through-
out the country have been quite tardy in grasping this idea and
have quite uniformly adopted milk ordinances which embody non-sens-

ical clauses and unattainable requirements. Dr. Charles E. Varshall
ably and correctly states a present day fault where he says: “We

preach what we do not know, we expect ideal conditions where only

101°755
fair are possible, we advocate the things of the millenium when
we are just emerging from barbarity.

It is the purpose in this article to briefly consider the
factors most commonly entering into city milk ordinances. This
makes possible the treatment of an immense and almost unstudied
field but I wish to narrow my subject still further and consider
these factors from the producer's standpoint. This side of the
question has received but little attention, it seldom comes to
light, and is less understood than that of the consumer. Very few
facts have been compiled in regard to it, largely due, perhaps, to
the lack of organization among farmers and the application of scien-
tific, business like principles to the business of milk and crean
production. <A sane and conservative consideration of the milk ques-
tion can never be possible until the consumer knows what the pro-
ducer has to contend with, the cost of producing milk, and the
steos in manipulation necessary to the securing of pure.milk. This
knowledge must furnish the appreciative spirit and rational inter-
pretation of the milk question.

In a consideration of milk and milk legislation we should
state definitely, at the outset, what ideas we wish to convey in
the use of these terms. Every medical college, every bacteriologic-
al institute, and every health commission may adopt a different

meaning for the term milk. In this paper I shall consider milk as

an opaque, yellowish-white, mammalian secretion with a slightly al-

kaline reaction and a faintly sweetish taste. It is composed chiet -
ly of water, proteids, fats, sugars, and minerals, together with
coloring matters, gases, and some organic acids. The relative Te
portion of these constituents will not be considered here because
they vary in the different breeds of dairy cattle and among the in-
dividuals in the same breed. There are several terms applied to
the various grades of milk, such as, selected, inspected or guar-
ranteed, certified milk, etc. These terms all refer to the condi-
tions under which the milk has been produced and handled,

City milk ordinances naturally refer to ordinances, of cities
of any size, which deal with dairy and food products resulting
therefrom. The ordinances are made up of rulings of the boards of
health of the respective cities which are to control the production,
care,and handling, of milk shipped into those cities. Furthermore,
in most cases, they have gradually come to include the health of
the cows, the treatment of the milk by the consumer, especially if
kept for a time, and the health of all persons concerned in its
handling.

It is not the purpose in this paper to pick flaws, primarily,
in any particular city ordinance, or to find fault with any partic-
ular board of health, but to present an orderly, unprejudiced study
of the so-called "milk question" from the producer's standpoint.

I shall endeavor to find if the average ordinances are constructed
with the purpose of serving the producer as well as the consumer;
to find if there really exists a strained relation between the pro-

ducer and consumer, and if such a relation does exist, to find its

causes and its cure; and lastly, to briefly glance at the problen
pro duct
of producing a cleaner dairy,at a less cost, or, at least, with

a very slight increase in price. I take up this subject from the
standpoint of the producer, both from a natural inclination to

that point of view, and because I believe the farmer has been un-
justly ignored in this subject in which he is most vitally concerie¢

There can be no question raised but that milk legislation is
absolutely necessary. Every branch of industry is governed by ap-
propriate laws because the need of some control is necessary to
protect and encourage both producer and consumer, In general the
producer of dairy products is the farmer, the world's largest la-
boring class. (we find among them men who may be classified accord-
ing to the quality of milk which they produce. Some produce an al-
most ideal milk: some only a ready-selling grade; others an article

which is not fit to sell and is positively dangerous to use; while
a few, although they may produce a good clean milk, employ one or

many ways of adulterating it before placing it on the market. The
last two classes named are a menace to society in general and must
be ruled by the law.| They also injure the reputation of the better
classes of producers and cheapen their product. Legal control just-
ifies its existence in being a corrective and a preventitive agent
over the cheater, and a protection to him who combines quantity and
quality inhis product.

[When we consider the consumers, they who consume the milk but
in nowise aid in ite production, we also find various classes.
One class is composed of a few individuals who recognize and appreci-.
ate good milk; another comprises those who are ignorant of every-

thing pertaining to milk; through this ignorance they allow the
milk to spoil,very many times, and place the blame on the ceases |
er; a third class is of those who do not know good milk and could-
n't or wouldn't buy it if they did. ‘This last class presents
another phase of the milk question, but one which is entirely
without the scope of this paper. The ordinances are almost wholly
designed to protect the consumer, regardless of the class to which
he belongs, but they do not place any restrictions on them govern-

ing their relations with the farmer. Milk ordinances should offer
some protection to the producer as well as to the consumer,

Finally milk legislation is necessary to improve the dairy
industry. In 1893, Dr. Henry L. Coit, of Newark, N. J., recognized
the inadequacy of state and municipal methods of dealing with the
milk problem. He and his associates organized a professional or-
ganization known as the Medical Milk Commission of Essex County,
New Jersey. The objects and scope of the commission were defined
as follows; |

"The objects of this commission are to establish correct
clinical standards of purity for cows' milk; to become responsi-
ble for a periodical inspection of the dairies under its patron-
age; provide for chemical and bacteriological examinations of

the product, and the frequent scrutiny of the stock by competent

veterinarians; to promote only professional and public interests.
This movement spread slowly because the question of milk im-
provement was not broadly understood by the medical profession, and

because, when an organization of a milk commission was decided up-
on, it wae difficult to arrive at the most acceptable plan of or-
ganization and detail of working methods. Usually the procedure
followed was to correspond with one of the older commissions, whic:

would relate its individual experience of handling the probdlen.
Usually all the commissions would be written to for information.

After a time it proved burdensome to the operating organizations,
and, wery often, unsatisfactory vo the organizing eommission. As
@ result there became visible a lack of uniformity as to organiza-
tion, working methods, supervision of dairies, chemical and bacter-
ijologioal standards, etc. <A conference of milk commissions was
held to decide upon the most acceptable standards and working fac-
tors. From this grew the permanent organization of the American
Association of Medical Milk Commissions. The original purposes of
the association are best defined by Article 11 of its constitution:

* The purpose of this Association shall be to federate and
bring into one compact association tne Medical Milk Commissions

of the United States; te exchange views and to adopt uniform
methods of procedure in the work of the Medical Milk Commissions:
to fix chemical and bacteriologic standards; to determine the
scope of medical and veterinary inspections, and to fcSter and
encourage the establishment of Medical Kilk Commissions in other
cities.,*

This is in brief the history of milk legislation to date. The
purposes of all organizations wererightly intended and were in tic
right direction, but in no case has the aim been broad enough, or
the method of procedure been such as to include the producer in the

construction of the legislation or to make it worth his time and
labor to live up to the imposed rulings. Milk legislation has de-
veloped, therefore, in a narrow and one-sided way, successful to «4
degree, it is true, but the problem is as much a problem today as

in 1893, and will continue thus until milk legislation is produced
by all concerned.

Up until the present time the various boards of health have
maintained that in every city a license must be obtained before the
privilege to sell milk is granted. This arbitrary demand has never
been questioned by the producer and he has always procured the de-
sired license. The producer admits the need of uniform standards
for all dairy products, for he poesesses enough common sense to sce
that they are necessary for the protection of the coneuming public.
Moreover, he himself enjoys a protection under these same standard:,
and also makes a financial prefit because of them. Further, he ad-
mits the need of inspection, the advantages arising from it, both
to himself and consumer, and in nearly every case is perfectly
willing to allow an inspection of his buildings and premises. Tast-
ly this same individual, or class of individuals, agrees with the
general public that there must be an enforcement of the law. fFror.
this it woutd seem that tne farmer has met the health commissioner
and consumer half way, yet he is not allowed a representation in en;
city council to present his side of the milk question and to share
in regulating his own business.

We are then face to face with one phase uf the problem, namely,
the so-called milk question is the result of certain groups of pro-

ressional men taxing the stand tnat tne farmers, ar a class, are in-
competent for consultation as to how to improve their own business.
Tne consumer does not come under the control of the ordinances and
the producer is at his mercy. There is no incentive for the farmer
to improve the quality of his milk. In tne main the health commis-
sions purpose to benefit the farmer with suggestions, but he resents
their attempts and with reason. In most cases the attempt to im-
prove the milk supply through the ordinance is characterized as a
‘fight for pure milk and as such has been received by tne farmers.
It is not an unwillingness on their part to improve their product
But rather a just resentment of the tactless, overbearing attitude
of health officers and inspectors, and of being compelled to meet
requirements of doubtless value and without proportionate compenss-
tion.

We will study the milk legislation which has been produced by
the boards of heath, principally of the cities of Micuigan with
perhaps one or two exceptions, under the impetus and infiuence of
une American Association of Medical Milk Cummissions. We will en-
deavor to find wherein this legislation is beneficial and where not.
and finally we wili glance briefly at a new system of milk inspecticy
and methods for securing improvement of the milk.

Practically every city milk ordinance demands that a license te
procured from the city clerk before permission shall be granted to
any person to engage in the sale, delivery or distribution, of milk
or cream. AS provisions to be complied with before the license is
granted, the applicant must pay a license fee; give his full name

and address; the name and addrees of all from whom he may obtain milx
or cream, together with the number of cows in his herd, as well as
of those from whom he Buys; he must also state the manner in which
he proposes to dispose of his product, Thus far most ordinances
agree, in content if not in form, but these are only details of lit-
tle importance.

The first important factor considered by boards of health is
generally approached in the following way;

“No person, firm or corporation, shall keep, offer or expose
for sale, or sell or deliver for sale or sonsumption within the
city of whether licensed under this ordinance or not,
any unclean, impure, unhealthy, unwholesome, or adulterated milk
or crean.®

They then proceed to state under what conditions will milk be con-
sidered by them to be "unclean, impure, unhealthy, unwholesome, or
adulterated." Suppose, for simplicity and clearness that we consid-
er some of these points as taken from some typical ordinance, in
which they may supposedly be arranged in a logical order.

"Milk or cream under the terms of this ordinance shail be
held to be unclean, impure, unhealthy, unwholesome or adulteratec,
when;

(1) Milk or cream is produced in filthy, foul smelling or
poorly ventilated stables, or when placed, kept or stored in un-
clean utensils, cans, or botties.®

Tnis section is acceptable in every way. Any one who is at all
acquainted with the nature of milk knows that it cannot be clean,
chemically or biologically, or free from foul taints or odors, if it

is produced under filthy conditions. Then, too, unclean utensils,
whatever their nature, mean unclean miik, for bacteria are always
present in unclean utensils, and they multiply readily in milk be-
cause it is a perfect natural media. It matters little whether the
milk in such vessels is "placed, kept, or stored," in them, contar-
ination takes place instantly and multiplication begins at a very
rapid rate.

(2) “When the milk or cream at any piace between tne point
of produetion and the place where it leaves the control or posses-
sion of the licensee, shall be placed, kept or storeé in any uten-
eil, bottle or vessel of any description that has not been ster-
ilize@ in a manner or method approved by the said board of health.)

The point intended to be em phasized in this section is well taken
but hardly seems of sufficient foree. An acquaintence with the or-
dinance of which this section was a part, and a limited acquaintence
with the board of health which formed this section, fails to show
that the expression "sterilized in a manner or method approved by
the said board of health® has not been elsewhere explained or more
definitely stated. It is immaterial in what manner or method the
thermal death point of bacteria is reached, so long as that method
gives effective results, but many other ordinances state the desired
principle in the following, definite terms:

®All cans, bottles, or vessels of any sort used in the sale,
delivery or distribution of milk or cream to the consumer must be
cleaned and sterilized (boiled, baked, scalded or steamed) by the
milk dealer before they are used again for the same purpose. *

(3)*Wnen the milk is drawn from a cow that has not first beer

properly cleaned, or when milking is done with hands that are not
clean and dry,.*
[p is a just requirement but which will only be met willinc-
ly arid voluntarily by the intelligent dairyman. Different men have
uifferent ideals of what constitute clean cows, and consequently a
cow which one man would consider quite clean, cthers would consider
positively fiithy. 8 ome men may milk cows which have manure plés-
tered thickly to their hips and sides but they never think of then
as being dirty. Cows may even have their udders more or less cov-
ered with manure, and even then some men would only consider them
a little dirty. In such cases the only care taken is to prevent
the manure from falling off into the milk, but ewen this is thought
by some to be removed by the strainer. |

MAded to this filthy condition is that of moist milking. The
hands may be clean, though more often they are not, and the milker
wilt first milk into his hands and likewise wets the teats. If the
udder and teats are filthy moist milking dissolves the filth and it
vannot be strained out of the milk, once it falls in. There are
ways in which moist milking is carried on which are infinitely more
filthy than when the moisture is from milk. At best it is a very
filthy practice and is unfortunately too difficult of detection.
Milk produced in such a way deserves all the words used in this
section to classify it properly.

(4) “When the milk is not immediately removed from the sta-
ble after milking and cooled to a temperature of 60 degrees or
less, and thereafter continuously kept at a temperature of not to
exceed 60 degrees Fahrenheit until delivered to tne consumer.*

It would be an approach to the ideal way of handling milk if this
section were carried out in full. In most cases the farmer must
be educated on the points connected with the production of milk.
This section enumerates two of those points, namely, contamination
of milk due to expoeure to impure air, and the effect of tempera-
ture on the germ content of milk. When the farmer realizes the ex-
tent of the contamination possible through exposure to air then he
will begin to reorganize his ideas regarding his business, and he
will endeavor to learn new facts concerning it.

Such a realization, however, has come to bvut a few farmers.
We seldom meet the ideal but the absence of it, otherwise our milk
problem would likely be short lived. The farmer does not as a rule
understand the possibilities of contamination and so sanitary meas-
ures are useless. Besides being uninformed he usually has his barns
all built and they have been good enough, previously, and ought to
be satisfactory now. If he doesn't live by the rule “what I've gut
is good enough,® then the cost of rebuilding will prevent many im-
provements. Many farmers have suitable barns but think they can't
afford to give up any space for a milkroom, or they keep the horses
in the same barn with the cows and a milk room separate from the
barn will be necessary. Whatever improvements might have to be msiie
most farmers would feel that the cost would exceed the resulting
benefit.

In order to secure the required temperature it would be neces-
sary to have ice. It seems to most people that it would be an easy

matter to have ice in the country and they are justified in thinking
so, tek more city homes will be found supplied with ice in summer
than will country hones. The reason is easily apparent. In the
city some man or firm makes it a business to store up large quanti-
ties of ice, then in the summer he sells it out at a price which
pays him for his work and property invested. It costs the farmer
just as much to fill an ice house as it does the city man, and he
must have a similar equipment, but he doesn't get sufficient remun-
eration for his work. The cost of securing an ice supply, the
building of an ice house, and supplying other facilities necessary
to cool milk and keep it cooled, raises the cost of production per
quart on milk, but the consumer won't pay more for it. The needed
reform in this case is opposed by the consumer not the producer.

It so often happens that the farmer refuses to build an ice house,
put in ice, and furnish an arrator, that the consuming public has
come to think that the farmer is too ignorant to see that he is
cutting off his own nose, The farmers are not organized and as a
result no one individual can effectively raise the price of his
milk and so pay for modern improvements,

(5) “when the omer or owners of the milk or cows refuse to
allow the proper agents or inspectors of the board of health to
make inspection and investigation as provided by this ordinance."

Most farmers admit the need of inspection and most of them are will-
ing to have their milk, cows, or barns inspected. Some farmers, it
is true, are opposed to inspection at first but in most case that
opposition has arisen from treatment received at the hands of in-
spectors. The boards of health are themselves at fault in this

point for they seem to think any man whom they authorize to go out
as an inspector is scupetent to inspect. The public knows of too
many cases where inspectors secured their jobs through political
pulls. Progress can never be made through inspection so long as
farmers know that their dairies are being scored by a man who does
not know enough about the business to judge fairly. An inspector
should understand that his presence on the farm is a mutual courtesy
and that his duty is to observe and record conditions as they exist.
If he is beyond the limits of the municipality he is entirely with-
out authority to issue orders, and his assunption of authority, whic!
the farmer knows he does not possess, is a common and fertile source
of friction. When the health commissions learn to consider this in
authorizing their representatives to act as inspectors, and when in-
spectors bear in mind their relation to the board of health and the
farmers, there will be no trouble encountered against inspection.
(6) “When milk is drawn from any cow less than twenty days
before or within five days after calving."
It is seldom that a cow will continue in a flow of milk right up to
the time of calving, and as a rule, the flow has ceased, naturally,
six or eight weeks before that time. It is considered advisable to
discontinue milking about that long previous to calving in order
that the cow may be allowed to rest and devote all her energies to
the development of the foetus. The time limit, therefore, preceding
parturition is of about the right length. The milk produced at this
time is called colostrum, and differs in the percentage of its con-
stituents from that of regular milk. It sometimes has an unattract-

ive appearance eventhough it is perfectly clean. It is by nature a
perfectly balanced ration and is primarily intended for the young
calf because it is a laxative and is highly important for cleansing
the alimentary tract and properly starting the work of digestion.
Very many health ordinances place this limit at ten days but it is
generally considered unnecessary.

(7) “When the milk is draw from any cow suffering from any
disease, or disease or injury of the udder or teats, or the milker
is afflicted with any comnunicable disease, or within twenty four
hours prior to the milking has been in contact or caring for any-
one afflicted with a communicable, disease.*

Cows, like human beings, may be troubled with a disease which may
exist unnoticed for an indefinite time. Also, cows may be poesessed
of various different diseases without impairing the quality of the
milk as a food, and apparently without affecting their health as
shown by appearance, condition, or action. The first clause of this
section is based on the erroneous belief that microorganisms have
access to the milk ducts and cisterns through the interior walls of
the udder, but such is not the case in a healthy udder, regardless
of most any disease affecting another part of the cow's body. There
are three conditions under which pathogenic organisms can gain ac-
cess to the udder; viz; (1) through the orifice at the end of the
teat when it comes in contact with any contaminated surface; (2)

through the tissues of the udder when the cow is suffering from some
disease localized within the udder, or within or upon the tissues
of the udder; (3) through the tissues of the udder when the cow is
suffering from some generalized disease.

In the first case we have found that there is no practical
way of preventing contamination but nature has a way of holding it
in check. The milk, while still contained in the udder, seems to
possess some characteristic germicidal property which prohibits the
growth and life of microorganisms. Organisms have been injected
into the udder but they were found to have perished in a short tinue.
Therefore, in addition to the difficulty encountered by organisms
in gaining an access to the udder, their sojourn there is usually
short. Some organisms can maintain themselves there, however, but
develop very slowly. After they are excreted with the milk, a low
temperature prohibits their growth, but they are not a type which
produce any marked changes in the milk.

A disease which is generalized, or which is localized in the
udder, would produce the same results so far as the contamination
of the milk is concerned. In either case there must first exist a
pathogenic change in the tissue of the udder. When this condition
maintains, pus is usually given off. Pus is generally a virulent
mass of streptococci and is more or less dangerous to human beings.
Conn believes that where they exist in the single coccus form they
are harmless. His theory, however, has not been substantiated by
experimental proof. However, under a diseased condition of the ud-
der the streptococcus forms are apt to be very numerous and the
milk to become a dangerous carrier of disease. Legislation, then,
against milk produced from a diseased udder is a step in the right

direction.
It ought not to be necessary to have to include in a milk or-
dinance a section to prohibit a man from selling milk when he is
afflicted with a coramunicabdle disease, or when he has recently been
an attendant upon a person eo afflicted. However, we know that peo-
ple exist who would continue to deliver their milk under almost any
circumstances until compelled to stop by legal authority. Fortun-
ately such people are not in the majority and undoubtedly very many
persist in such a practise because of ignorance of the suffering
which they may cause. There are many phases of the milk question
which are dependent for their final solution upon the education of
the public, and this can be included among them. .

(8) “When the milk is drawn from cows fed wholly or in part
upon the waste of distilleries or breweries, or brewers! grains in
a fermented mndition, or upon any other food or drink that is
known to produce tainted, impure or unwholesome milk."

There ;is a wealth of evidence to support this section. Its purpose

really is, or should be, educative as very many farmers may innocent:

ly taint their milk by feeding something which they supposed to be
a good, healthful feed. *Dr. Henry writes on the subject as follows
“Owing to their volume, their watery nature, and their perishable
character, wet brewers grains are usually fed near the brewery. In
the hmds of greedy persons, cows have often been crowded into dark,
illy-ventilated sheds and fed almost exclusively upon wet brewers’
grains. Sometimes the grains have partially rotted before being
fed, and the drippings getting under feed boxes and floors have on
fermenting produced sickening odors. Under such circumstances it is
not surprising that boards of health have been led to prohibit the

sale of milk from such dairies. There is nothing, however, in fresh
“Henry »Feeds and Feeding."
brewers' grains which is necessarily deleterious to milk. Supplied
in reasonable quantity, and fed while fresh in clean, water-tight
boxes and along with nutritious hay and other roughage, there is no
better food for dairy cows than wet brewers' grains. So great is
the temptation to abuse, however, that wet grains should never be
fed to dairy cows unless under the strict supervision of competent
officials. If this cannot be done, their use should be prohibitec.”"
In regard to other foods, drink, or drugs, Leblanc writes:*
® It is well known that certain drugs are eliminated by the mammece,
their presence being detected in the milk, communicating to it their
taste and properties. Guinard has detected certain bitter and pur-
gative agents; Baum, tatar emitic; Klingemann, alcohol; Fubine and
Bonani, atropine; Gunther and Harms, camphor, ether, turpentine,
assafoetida, and chloroform; Hertwig and Spinola, aloes and arsenic;
Fubine, strychnine, salicylic acid, carbolic acid, lead salts, mer-
cury, iodine and the alkaloids of opium. The milk of animals fed
on certain plants, especially garlic and turnips, is tainted with
the characteristic smell, also that of goats in certain localities
in which wild thyme abounds. Cows fed on the refuse pulp from
beet-root sugar factories give milk of a mawkish, unpleasant taste."
(9) “When any milk or cream contains any substance not a
matural or normal constituent of milk or cream.*®
This section is far more inclusive than it is probably generally
considered to be, or perhaps than it was originally intended to be.
It undoubtedly refers to the presence of water, in particular as
that is most commonly used for purposes of adulteration, or to

* "Diseases of the Mammary Glands of Domestic Animals" Leblanc.
form alfi, or other preservatives. Adulterated nil snould be dis-
countenanced severely, and preservatives in milk are entirely un:<«c-
essary even though they might not be injurious. However, as now
worded, this section includes dirt and filth of any kind as well «5s
bacterial contamination. As is well known milk can not be produce,
commercially, perfectly free from bacteria, and only under the best
of care can dirt be kept from it, but that doesn't mean that legis-
lation should not aim toward securing such a product. Legislation
can only be one of many contributing factors in guarding against
adulteration or in securing pure milk in other ways, but as such it
should be welcome.
(10) “When any milk contains more than €8 percent of water

fluid, or less than 12 percent of total milk solids, or less than

3 per cent butter fat, or when any cream contains less than 18 :+>

cent butter fat.*
Each state adopts standards of its own for the percentages of the
constituents of milk and cream, and most cities adopt these stanc-
ards for their milk ordinances. This particular ordinance, which
I am quoting, would receive milk which might be seized by state i:-
spectors as watered milk, as the Michigan State Law will not alls"
milk "by weight to contain more than eighty-seven and fifty one
hundreds percentum of watery fluid." This section would also viol:::
the Mihm igan State Law in that the law specifies that milk is nct
"to contain less than twelve and fifty one hundredths of milx solic:
per centum.* Most of the cities of Michigan copy the state standur’
in their ordinances or make the requirements more stringent. The

state standards as quoted above, together with the requirement th::t
there must not be "less fat than three per centum," are about the
average percentages for ordinary milk. Such a standard, therefore,
is no hardship to the producer, but is, rather, a protection against
the practices of the unscrupulous milkman,

(11) “When milk or cream shall contain more than 200,900
bacteria per cubic centimeter if milk and 500,900 per cubic ceniti-
meter if cream, on two successive counts from samples collected
by some member of the board of health, or a duly authorized rep-
resentative thereof.®

This section has become of so great importance to members of nearly
every board of health that they have one and all been led far astray.
That which should only be taken as an indication of cleanliness has
been adopted as an absolute standard. The method of counting is
inaccurate at best and besides we should not be so much concerned
with the number as with the kind of bacteria found in milk.

"*In the interpretation of the results of the numerical deter-
mination of bacteria in milk, it must be constantly borne in mind
that the results indicate only conditions at the moment the sample
was taken. We are not dealing with the quantitative estimate of a
milk constituent like fat, which is present in the same proportion
in a given sample at all times. It must be remembered that a bac-
terial count is a measure of the progress of mltiplication of a
complex mixture of micro-organisms, controlled by an equally com-
plex series of factors. The results at any given time depend in

part upon initial numbers, species, characteristics of the milk,

*Ward; “Pure ilk and The Public Health."
its age, the temperature at which it has been kept, and the method
of making the determination. Wrong conclusions will be reached, if
emphasis is laid upon mere numbers without a consideration of the
other factors.

A numerical determination taken by itself without full consic-
eration of all the factors involved has no value. fFersons not fa-
miliar with the circumstances are apt to attempt to make compuaris::s
where such are inadmissable. The results of the work of two labori--
tories cannot be compared, unless there has been uniformity in ever;
detail that would affect results. Every bacteriologist doing muc:i
milk work has had embarrassing experiences along this line. The
wan wno has had the longest experience with numerical determinations
of bacteria in milk in connection with miik commission work believes
that no good end is served by stating results pubsicly in numerical
terms, and acts in accordance therewith.

The vacteriai count is unuouvteday the instsument by which the
effectiveness of good dairy methods is measured, and has been a
prominent factor in the development of those methods. [t reveals
facts regarding the operation of higt grade dairies that no inerec-
tion could disclose. A count of certified milk is better evidence
of observance of certain features of cleanliness in handling the
milk than a visit to the dairy.

* "© While the germ content may we regarded as a general index to
the care the milk has received, it may not at all indicate its whole-

someness. A high count may be the result of the rapid growth of

* Marshalls: *® Micro-Bilology.*®
the lactic bacteria, in which case the milk may be perfectly safe
and wholesome. Qn the other hand the count may be quite small but
contain pathogenic species. The bacterial count is valuable as
showing the sanitary conditions of production and handling, but
much care should be used in the interpretation of such results. In
some ways a direct microscopic examination of the milk sediment is
much more satisfactory. The skilled analyst can recognize certain
types and species which may indicate the sanitary quality of the
milk, With sufficient experience one can recognize streptococci,
B. subtilis, organisms of the B. coli type and some of the putrefac-
tive species and leucocytes. The presence and abundance of one cr
more of these groups may indicate the nature of the original con-
tamination and the existence of diseases in the udders of cows. If
rightly interpretated the information thus obtained is of much val-
ue. The weakness of this method lies in the fact that it is not
always possible to recognize the above types of organisms. Ina
smear preparation it is not p@sible to differentiate between patho-
genic and non-pathogenic streptococed or between B. coli and certain
other types. The presence of unusual numbers of streptococci and pu
cells may indicate the existence of disease in the cows and when
this condition is found in the city milk it is possible to trace it
back to the farm and locate the diseased cow and prevent her milk
from being used for human consumption.*

Slack has observed that, in connection with his method for the
study of milk sediments, the number of bacteria may also be roughly

estimated. By a long series of comparative tests, it has also been
found possible to tell from the number of bacteria in the smear
whether or not plate cultures would show above or below 500,000
colonies per.cc. An error of less than 1% was made in this regerc.
He uses the test to eliminate those samples of milk that are well
within the limit, and thus saves the trouble of plating them.

The committee of the American Public Health Association in
its 1908 report makes the following comment. Several laboratories
are now making this examination as a routine procedure. One work-
er (Conn) , who has done considerable experimentation along this li
during the past year, sums up his results in attempts to actually,
approximate plate counts as follows;

® *The method seems to be fairly satisfactory for milk, the
bacterial content of which is not too low or too high. When the
numbers are down below ten thousand the method seems to be quite
inaccurate, and when the numbers run up into the millions, I find
also the numbers are not vwery reliable. Within the limites of from
thirty thousand to three hundred thousand, however, the method
seems to be fairly good. I have, however, had the experience of
occasionally finding samples of milk which, when tested by direct
microscopic method,‘ gave results very different from those by the
plate method. My general feeling is that a direct microscopic
method might give an idea as to whether the sample is very good or
very bad, but would not replace the plate method of examination in
determining actual numbers and would be of no use for the examin-
ation of samples of milk whose number of bacteria is quite low.

* another (Campbell), who has done much work with this method,
finde it chiefly useful as a preliminary test, not plating samples
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which are shown by the microscope to contain less bacteria than the
city regulation permits, in those samples which are plated it serve:
as a guide for the proper dilutions. He finds it possitle with this
examination to correctly state in nearly every instance when a mick
contains less than 50,000 bacteria to a cubic centimeter, or when it
contains over a million bacteria to the cc. On actual estimates
within 50,000 of the plate count his average is 66% correct on count
between 50,000 and 500,000, and 50% correct on counts between 500,(C
and 1,000,000.®

The quotations from Ward and Marshall reveal fairly the atti-
tude of fair minded bacteriologists toward the accuracy and value cf
bacterial counts in milk. The reader can readily see that it is 1st
a method of mathematical accuracy and i8 18 not of definite value.
The comment quoted from the 1908 report of the committee of the
American Public Health Association should show the reader that the
methods of counting are still in the experimental stage. The plate
method of course is the old method and is completely developed but
it is cumbersome, takes a great deal of time, and, if truth is tolc,
is far from accurate.

To one, therefore, who holds this attitude, the standards fcr
bacterial counts in milk do not mean much. A little study will ehov
that the health commissions of different cities disagree on the nir-
vers of bacteria which can be safely allowed. Indeed, a little
study will show a wide variation in the bacterial count allowed by
any one city at different times. This would seemingly indicate that
the bacterial count is not a matter of life and death to the extent
 

which some health commissions would have us believe; The experi-
ence of some cities has shown, too, that it is not a matter of econ-
omic consideration as to whether the count is high or low. The
kind of bacteria in milk is equally as important as the number. Th:
tendency is beginning to prevail in some cities of combining the
quantitative and qualitative analysis, and the results thus obtains:
in the hands of the careful worker are of much practical value in
controlling the quality of the city's milk supply.

(12) "When milk or cream is kept in any place not screened

from flies or protected from fowls or animals."

It would require but very little expense for one to fit his milk
room to meet this requirement. The satisfaction resulting should
be ample reward, while in addition it would mean increased protec-
tion against disease to the producer's family. Probably few men
who realize the value of a milkroom sre so short sighted as to leav
it unprotected from fowls or animals. Screening against flies, how-
ever, is an entirely different matter. A great many people think
that the cool temperature of the milk room will keep out flies, and
it will to some extent, but occasionally the temperature rises or
a threatening storm drives them in. Once in they bring a thousand
troubles in, too. They may have just left the manure pile in the
barn, the edge of the cess pool, or the carcass of some dead and
decaying animal. If so the sticky pads on their feet are covered
with millions of filth and disease germs. Their feet come in con-
tact with the milk as they go to drink and these germs are released
in countless nunbers to develop rapidly and uncheoked, because of

the low Sexperatuts in the milk.
Primarily the screening against flies is a caution for observ-
ance by the producer. It goes still farther, in reality, and in-
cludes the consumer. The fly which enters the city home is just «és
much of a muisence and is just as filthy and dangerous as the countr;
fly. He may have just left the garbage can, the city sewer, or some-
thing even worse. He can pick up typhoid germs in the city and de-
posit them in the milk just es easily as elsewhere. In this case
an investigation would prove more difficult but if once made could
reveal the truth. “Suspicion, however, would be thrown upon the milk-
man. The milk supply is always the first suspected source of ty-
phoid but not rightly so.

(13) “When milk or cream is bloody or stringy.*
Bloody milk is usually the result of a physical injury of the udder
or teat and is not dangerous for consumption, but if detected the
milk naturally becomes an unpleasant food. Stringy or ropy creem
is due to an organism, B. lactis viscosus, which grows with great

difficulty at blood temperature and is, therefore, not a pathogenic

germ. *"These organisms grow most freely in the presence of an abun
dant supply of oxygen and for this reason the cream usually becomes

slimy before any changes become apparent in the underlying layers of
milk, Representatives of this group are quite resistant to heat and
frequently pass uninjured through the methods of cleansing @4d scalda-
ing used under ordinary creamery conditions. Because of this, dairy
utensils once infested become a constant source of infection. “Nei-
ther bloody or stringy milk or cream, therefore, is injurious, and,

though it is quite difficult to avoid, it is reasonable to legislate
against it. *W.A.Stockin in Marshall's "Microbiol:
(14) “When the room in which the milk is cooled or stored is im-

mediately connected with a stable in which animals are kept or

confined."
An ideal milkroom should at least be separated from the barn, but
ideal conditions cannot be expected on every farm. In very many
cases a milkroom is a part of the dairy barn but is partitioned off
from the rest of the barn. Undoubtedly such would be suitable in
most barnes if sufficient care would enter into the work and mater-
ial in building the partitions, Even with ordinary partitioning, I
think, the attached milkroom is satisfactory. If the feeding is
not done until the milking is finished, and if the stables are kept
clean, then the contamination must largely result right near the
cow while she is being milked. By using the covered small top pail
contaminatl on cannot readily occur in carrying the milk from the
cow to the milkroom. Within the milkroom the air can be kept in
circulation, and will then be fresh, end this in connection with a
low temperature will make any milkroom suitable. Under such condi-
tions, and with tle door connecting with the stable always kept
closed, no inspector's edict, based on any of these @ nditions, can
render milk "unclean, impure, unhealthy, unwholesome and adulterated

Other factors generally included in the milk ordinaces and whic

denote a trend in the right direction are as follows:

« The milk or cream furnished by every hotel-keeper, restaurent
keeper or boarding house keeper, to his, her, or their gue sts,
ehall be in all respects up to the standard herein sped fied, cth-
wise such hotel keeper, restaurant keeper or boarding house keeper

shall be liable to the pains and penalties of this ordinance."
Any dealer or producer in milk or crean who sends his, her,
ite, or their product to the city of for consunntion in
any form, and receives compensation therefor according to tre
percent of butter fat as shown by a test or tests made by such .::
ducer or dealer, is hereby required to make such test or tests
accurately and correctly, and to accurately report such to tne cu:
sumer. *

Skimmed milk or sour milk may be handled or sold if kept in
utensils plainly marked. Skimmed milk shall conform to the st#u'-
ards of purity and temperature required of sweet milk.

A license must be obtained before buttermilk can be sold in
the city of . All buttermilk shall be manufactwed from
pure cream or milk, and snall be kent, handled and sold in accorc-
ance with the provisions hereof made for keeping and handling
milk or cream.

All milk, crean, buttermilk or skimmed milk sold or offers:
for sale in bottles must be bottled at the dairy house, creavnery
or milk depot, and must not be put in bottles while on the road.
The handling of milk cans, bottles or other vessels in which mils.
cream, buttermilk or skimmed milk shall be delivered to or frou
the place of delivery, in wagons used for handling manure or svil1
or any other unclean vehicle, is expressly prohibited. Bottles
used as milk, crean, buttersilk or skimmed milk containers must
not be used for other purposes.

It shall be the duty of the inspector of milk to file a co--
plete record in writing of his proceedings as inspector, giving 3

full and accurate account of all inspections made, and of sanples
collected.

No ticket in exchange for milk or cream shall be used a sec-
ond time, except metallic tickets which may be used continuously
provided they are sterilized before passing out for use a second
time.

No person, firm or corporation, shall sell or offer for sate,
expose for sale, or keep with the intention of selling, any milk
or cream at retail unless the same shall be kept in a tightly cov-
ered receptacle or sold in bottles.

The milk or dairy inspector, the health officer or any other
person authorized by the Board of Health, may examine all dairy
herds, utensils for handling milk, of all dairymen or other per-
sons engaged in selling or shipping for sale milk or cream. These
inspectors shall have power to open any can, vessel or package
containing milk or cream, whether sealed (locked) or otherwise,
and take samples of the milk or cream for testing or analysis; and
if, upon inspection, the milk or cream is found to be filthy, or
the cans or other containers are in an unclean condition, the s-id
inspector may-then and there condemn the milk or cream as deemed
by him to be filthy and pour the contents of such bottles, vessels
or package upon the ground forthwith, and he shall, if done in
good faith, be held harmless in damages therefor, in any suit or
demand made.

It has been charged by many producers in a number of section:
contiguous to Detroit that often times these inspections were unfai

and were made by incompetent men. As a measure of mutual protectis
local organizations of dairymen in different sections of contiguous
territory eprang up. A general organization was later consumated,
and after a time this was reorganized and made to include practiczl-
ly all of the local organizations. This was known as the Mutual
Deirymen's Association of Detroit. It numbered over eight hundred
members and represented between nine and ten thousand dairy cows,
the milk from which contributed to the Detroit city milk supply.

There has existed since this organization considerable friction
between the association, the local board of health, and the milk
dealers of the city of Detroit. As a result the Association has
presented a bill to the State Legislature which has a strong bearing
on the sentiment of the last section quoted above, and reads as
follows.

Section 1. Any city board of health or its agents or inspec-
tors shall have the right at any time to inspect the barns, milk
rooms, milk pails, and other utensils, also the cattle of any per-
son or persons, firm or company producing milk or cream for city
consumption, and also all milk depots, shipping stations and ap-
pliances connected therewith.

Sec. 2. Any producer or shipper refusing to allow such in-
spectors to inspect their premises, barns, cattle and utensils
shall be debarred from shipping milk to said city, also any owner
of milk depot or creamery refusing to allow inspection shall be
debarred from shipping milk to such city.

Sec. 3. All agents or inspectors appointed by city boards
of health to inspect the buildings, cattle or premises and uten-

sils of producers shall have had at least two years experience in
managing or working on a dairy farm after having reached his
majority, but any city health board who shall have inspectors do-
ing such inspection when this bill goes into effect shall replace
such inspectors by inspectors of the above qualification as Rete
One inspector inside of ninety days after this act goes into ef-
fect and one additional inspector each six months thereafter un-
til all such inspectors are qualified as above.

“The Mim igan Farmer" said in part in discussing this act;

"It is said upongood authority that the board of health is prepar-
ing to make a strenuous fight against the enactment of this proposed
legislation. As a matter of fact, to one who has observed this con-
tention from the outside, it would appear that there are just ground
for dissatisfaction among the dairymen. There seems to be plenty of
evidence of incompetence on the part of some of the inspectors, «at
least, although it is stated upon reasonably good authority that

the board of health has sought to make an improvment in this direc-
tion. Also, there is no doubt that those who have this matter in
charge in the city health department are less able to give compe-
tent inspection that would be a class of inspectors coming up to the
qualifications advocated by the dairymen.*

This act, namely, the Downing Bill, and the criticism called
forth by it in the “Michigan Farmer" are in the right direction.
Inspection is all right but it must be done by competent men. The
Mutual Dairymen's Association of Detroit by their action plainly
Say as much. An inspector may have the right to pour out milk which

he sees fit to condem and he may escape demage for it, but he will
never win the cooperation of the producers for a progressive move-
ment. If aman possesses the qualifications demanded of an inspec-
tor by the Dowming Bill he will likely possess the good will of
most dairymen and to have tact, judgment and sense.

This is in brief an enumeration of the more important factors
of a city milk ordinance and a hasty consideration of each from the
standpoint of the producer. There is one factor, however, which
is particularly concerned in present day milk legislation but which
is not likely to be solved until some distant date. That factor is
tuberculosis. Before its importance and far reaching effects were
realized, it was enumerated among the ordinary chance diseases of
the dairy cow. Now emminent scientists believe bovine and human
tuberculosis to be identical, or at least that the bovine type is
transmissable to man, and it has become a question of world wide
consideration.

The cities of Mibizgan which have awakened to a realization of
the local importance of the milk question were not at all behind in
facing this new and growing phase of the question. Whether their
method of dealing with it may be right or wrong is a question for
future solution. In a proposed ordinance which was under consider-
ation early in August 1912, the Board of Health of Lansing, Michi-
gan, sought to deal with the question in the following manner:

"Milk or cream------shall be held to be unclean, impure, un-
healthy, unwholesome or adulterated------When milk is drawn froin
any cow that shall not within one year last past have been in-
spected and tested to ascertain whether such animal is affected

with tuberculosis or other contagious or infectious disease.
The inevection and test named in this subdivision shall be held
complied with if the owner or owners of such cow shall within one
year from the going into effect of this ordinance file in the
office of the board of health a certificate of a duly licensed
veterinary surgeon, or any other person given authority by the
livestock sanitary commission to make tuberculin tests, on blanks
to be furnished vy the board of health, stating that such cow
has been tested with tuberculin and examined and found free from
tuberculosis or other contagious disease."

The ordinance, of which this preceding paragraph was a part
of a sub-section, wes not passed by the city council because of tlic
dissatisfaction found with this specific section. Another ordinenc:
was drawn up and proposed to take effect Jan. 1, 1913. ‘In this or-
dinance the subject of tuberculosis was studiously avoided but it,
too, was rejected by the city council. The council felt the need
of adequate legislation on the subject of tuberculosis but felt tha
they should proceed cautiously and guard against measures either to
radical or so conservative as to effectively impede procress.

Grand Rapids, Midhigan, attempted to deal with the subject of
tuberculosis and drew up an ordinance containing a subsection rel-
ative to tuberculosis which was identical with that quoted from the
lansing ordinance, The city of Flint, Mihhigan, adopted a subsec-
tion in their ordinance which read as follows:

"It shall be the duty of the Board of Health to ascertain
that the cows from which the applicant proposes to obtein milk

for sale or distribution are free from tuberculosis and other in-
fectious or contageous diseases. No cow shall be considered free
from tuberculosis except after showing no response to the tuber-
culin test, ae applied by a duly licensed veterinarian. The cows
from which the applicant proposes to obtain milk for sale and dis-
tribution shall be examined by a licensed veterinary before the
City Clerk shall issue a license, and an examination of the cows
in the herd from which milk is obtained for sale or distribution
shall tbe made at least once a year thereafter, and each animal
tagged in a manner to afford a permanent record of the examination,
and no license shall be granted to any applicant until the cows
from which he proposes to obtain milk for sale or distribution ere
shown to be free from tuberculosis and other infectious and conta-
gious diseases. No milk or cream shall be sold or offered for eale
within the corporate limits of the City of Flint from any cow addec
to a herd until such cow has been examined by a licensed veterin-
erian, and upon such examination found free from tuberculosis and
other infectious and contagious diseases and such an examination
shall have taken place within six months from the time it is pro-
posed to add such cow to the herd from which any milk dealer or
vendor obtains milk sold or offered for sale within the corporate
limits of the city of Flint. In all cases the expense of the vei-
erinary shall be paid by the owner of the cow or cows.”

The City of Detroit, Miedgan, rules that no milk shall be solé

in Detroit
"Which is produced from cows which are kept or stabled under

unhealthful conditions, or which may be diseased; nor shall any

milk be sold or delivered in said city, which is procured from any
farm or dairy where any contagious or infectious or communicable
disease may exist."
The City of Battle Creek, Michigan, seeks to protect itself by a
subsection in the very same words. Traverse City, Michigan, words
its ordinance in part in the following way;

"It shall be the duty of the Milk Inspector when ordered to
do so by the council or board of health to inspect or cause to be
inspected the dairy or dairy herd of any such person so applying
for such a permit or who has obtained such a permit, or the dairy
end dairy herds from which the applicant obtains milk or cream
without any unnecessary delay and to examine each and every aninal
producing milk for sale or consumption in said city, belonging to
or controlled by any person having such permit, or the person
from whom such dealer obtains milk or cream, for the purpose of
ascertaining the presence or absence of tuberculosis or any other
contagious or infectious disease and in making such inspections
and examinations the inspector is hereby authorized to use what
is known as a tuberculin test, a diagnostic agent for the detec-
tion of tuberculosis in such animals. After such examination and
inspection of the dairy and dairy herds as in hereinbefore provid-
ed, he shall at the request of the owner of said herds tag each
and every animal so examined, which tags shall state the result of
the examination as regards the presence or absence of any conta-
gious or infectious disease, and the said inspector shall file a
report of the examination and inspection as herein provided with

the City Clerk, which report shall state what disposition, if any,
 

has been made by such dealer or the person from whom such dealer
obtains milk or cream, of the cows which were found to be infect-
ed with any contagious or infectious disease and whether or not
any such diseased animals are used for the production of milk or
cream for sale and consumption in said city.*

Such has been the legislation produced in the State of Michi-
gan concerning tuberculosis. It has not definitely been proven
whether bovine and human tuberculosis is the same diseage; but ex-
periments seem to indicate that they are. There will always be
some ground for discussion on thisquestion as there are scientists
of note who maintain that the two diseases are produced by differ-
ent types of organisms, and they can give strong arguments in su ,-
port of their contention. As the question cannot be argued here I
will simply quote the most important findings from the Final Report
of the Royal Commission on Tuberculosis. This report is quite gen-
erally accepted as the "last word" on the subject and is the unpre-
Judiced findings of several years of work by the best scientists of
Great Britain. The report reads as follows in parts, not quoted ér-
tire or necessarily consecutively:

"The only difference in respect of cultural cheracteristics
between the two types is that the human type exhibits a greater lux-
uriance on all the different media we have employed in making con-
parisons, and that although this difference is not md ntained with
absolute constancy, we have not in our cultural experiments observe
any case in which the mode of growth of the one tyne became so far
modified as to be indistinguishable from the mode of growth usual ly
exhibited by the other. But the point must be emphasized that the
bacilli which we have referred to as the tovine type vary consiceri:-
bly among themselves in resnect of luxuriance of growth, and that
the gap that sevarates those of them that grow most abundantly fr...
bacilli of the human type is not a wide one."

“Chief anong the differences between tEcvine and human tuberc!<
bacilli is, of course, difference of virulence towards certain ar:-
malea,®

“There would therefore remain only slight cultural differences
on which to found the conclusion that the human and bovine types rc:-
resent two distinct organisms. We prefer to recard these two tyves
as varieties of the same bacillus, and the lesions which they pro-
duce, wnether in man or other marmals, as manifestations of the s::.-
disease,®

“Whether one prefers to regard bovine tuberculosis and the carr:
of tuberculosis in man which are caused by the human tyve cf bocitii
as varieties of the same disease or as independent diseases, there:
can be no question thet human tuberculosis is in part identical vit)
bovine tuberculosis. Our researches have vroved that in a consider-
able proportion of cases of the human disease the lesions contair.,
and are caused by, bacilli which are in every respect indistinguis’-
able from the bacilli which are the cause of tuberculosis in cattle.
In all such cases the disease, therefore, is the same disease ag t-
vine tuberculosis."

"Ey subdcutareous froculation the human type has teen found tr “5
missable in some degree to many different syvecies of animals, but
for most of them transmission has been effected only by the erploy-

ment of large doses. In strong contrast to this emall liability of
certain of the lower animals to tuberculosis of the human type is
the susceptibility of animals generally to infection by the bacillis
of the bovine type (whatever the sourse, lower animals or man, of
such bacillus)."

“In cattle suffering from tuberculous disease acquired other”
than by experimental means, we have in no single instance detected
any but the bovine bacillus. We have conclusively shown that meny
cases of fatal tuberculosis in the human subject have been produced
by the bacillus known to cause the disease in cattle, and the pos-
sibility of such infection cannot be denied."

"Only rarely has a pulmonary lesion in adult men yielded the
bovine bacillus. Our experience of abdominal tuberculosis in the
human subject has been very different, especially as regards child-
ren. Of young children dying of primary abdominal tuberculosis,
the fatal lesions could in nearly one half the cases be referred tc
the bovine bacillus, and to that type alone. In children, too, and
often also in adolescents suffering from cervical gland tuberculosis
a large proportion of the cases examined by us could be referred to
the bovine tubercle bacillus."

"The evidence which we have accumulated goes to demonstrate
that a considerable amount of the tuberculosis of childhood is to b«
ascribed to infection with bacilli of the bovine type transmitted tc
children in meals consisting largely of the milk of the cow."

"Though of the fifty five cases of adolescent and adult tuber-
culosis which came under our scrutiny no more than five yielded bac-
illi of the bovine type, we cannot say that this figure adequately
represents the proportion of like cases obtaining among the tuber-

culous population generally."
From this report, therefore, we readily gain that tuberculosis
in cows endangers the use of milk as a food, and particularly so as
an infant food. Some sort of legislation is necessary consequently,
for the protection of human life against this disease. Likewise
some sort of protection is necessary for the farmer against the fun-
atic or crank on the tuberculosis question who would have every sus-
pected cow killed and burned regardless of the rights of the owner.
When the farmer has been educated to the prevalence of tuberculcsis,
its effect on human life, and how readily it can be checked and com-
pletely eliminated, then he will cooperate in the anti-tuberculosis
crusade,

What has been accomplished by this great agitation of the milk
question? What have been the results of these various ordinances
throughout the state and country? Some are mere words; some are
conservative in their requirements; others very radical; while a
good many are ridiculously unjust. In the first place the public
conscience has been awakened and the milk question has bemwme the
health question. The time was when farmers thought a certain amour?
of filth was a necessary constituent of milk and it can't be denied
but that some farmers still entertain the same ideas. The time was,
also, that the consumer thought he must take milk as it came to hin
or else keep a cow in his backyard. Constant agitation has done a
good deal toward removing those ideas but hasn't gone much beyond
that. :

A large business was now opened up, namely that of milk inspec-
tion, Health authorities stated facts to show that inspection was

necessary. The consumer was to receive the benefits of this insvec-
tion at a very slight, if any, increase in the price of milk, eo he
accepted the statements without further proofs. The burden of these
reforms were to rest on the farmer and he, therefore, naturally
called for proofs of the necessity of these reforms. The proofs
have really never been furnished him. Lecturers have graced and cis
graced Institute and Crange platforms, each and every one reiterat-
ing the way of increasing the milk supply, the necessity of rigid
inspection, but giving always a too superficial consideration of tre
milk question to answer the "why" on any phase of the question. As
a result the farmer knows the threadbare old story but has never
seen it proved. What do the majority know about bacilli, cocci,
streptococci, etc., until they have actually seen them? What does
“clean up" mean when its actual significance in relation to contam-
ination of milk is unknown? What does the farmer know about bacter-
ial count when a drop of milk looks the same whether it possesses
ten thousand or ten million bacteria? The farmer may have a good
meny things to answer for some day but more responsibility will rest
on the educated man who has seen and who knows but hasn't attempted
to impart his information.

In spite of the fact that the farmer has not been satisfied on
the justice of the demands of the health department, he has taken
the authorities at their word, though often with little grace, end
has made improvements, Better stabling conditions exist in most
barns; feeding time in relation to milking is now considered to rre-
vent contamination of the milk by unnecessary dust; milk houses have
been built; milk has been drawn under more sanitary conditions and

has been cooled properly; more attention has been paid to the chemic
composition of milk and this has led $6 more rigid selection and
judicious breeding of dairy cows, coupled with scientific methods
of feeding; and, lastly, much good has been accomplished in the in-
sistence on bacterial count.

Now that clean milk is becoming more readily available each
year what is the attitude of the consumer? Some of them appreciate
the advantages they can now enjoy and are maintaining an interest in
the milk question and in the production and care which the milk re-
ceives. Others are not appreciative and are just as much a dead
weight on the milk question as is a careless, unprogressive farmer.
It is not possible to discuss the mental attitude of consumer tow-rc:
the producer, and vice versa, but it is, nevertheless, a significent
fact that the consumer, who does understand and appreciate the farz-
er's side of the question, and who performs his part in looking of-
ter the care of the milk and of the bottles while in his possession,
arouses a mutual interest which results beneficially for all concern
For such customers the farmer is willing to produce a better quality
of milk and deliver it in better condition.

Those who are a stumbling block in the milk problem do not rec-
ognize the total loss to the farmer each year for which they them-
selves are responsible. When their milk is delivered in the early
hours of the summer morning it is put in a shady spot. It is very
often left, however, until it has long been exposed to the sunlight
and heat; as a result it sours readily. Very often it may be left
s0 exposed in an open dish and many organisms including pathogenic
germs may enter, These things all count against the farmer for the

true cause of the trouble is seldom set forth. Then in very many
cases the consumers ere careless about the milk bottles; they are
used for household purposes, are given to the children to play with,
or are carelessly throw into the garbage barrel. ~-

These are an injustice to the producer and he should receive
protection from them through the ordinance. Such conditions are
bound to create false relations between the producer and the con-
sumer, ‘The consumer often thinks he is being cheated because it
could be done and he couldn't detect it; the producer knows he is
being treated unjustly because he knows his milk will withstand sour
ing for a certain length of time under fair conditions, and because
he can reckon his loss daily in missing milk bottles.

It is reasonable to expect that laws which are partial to cer-
tain classes of individuals would not tend to develop industries
maintained by the individuals they oppress and such is the case in
actual practise. The farmer naturally will always ask, previous
to making any improvements, "Will it pay?" In every case reasonable
improvements in the dairy business won't pay for the consumer will
not pay a sufficient price for superior quality of milk. This is
| not always the case, as it depends largely on geographical location
and the nature of the availabk markets, but it is so often the cass
as to effectively retard the developement of the dairy industry.

The farmer must be assured that he shall not be obliged to sustain
losses incurred by the carelessness of others or by their flagrant
disregard of his rights. He must have the assurance of protection
from the acts of unscrupulous and incompetent inspectors; and, fin-
ally, to uplift the dairy business, the dairy man must be given rea-
son to think that his work is a work of dignity and importance. Cfuc
a condition can never be brought about untii the general public
cnanges its opinion about the farmer; until ne is given a voice in
the formation of milk ordinances, and until a milk ordinance means
justice, protection, and encouragement, for him as well as for the
consumer.

There is an old word which is now rapidly coming into general
use, and that word is "cooperation." We have seen in almost every
Kind of industry what can be accomplished by cooperative efiaort, anc
we know that the rarmers, ulthough slow to grasp the opportunity,
are beginning to orgmize and cooperate. We hear of cooperation
among the fruit growers, among the wheat growers, and among stock
men, It is but a small step from cooperation among live stock men,
many of whom are dairymen, to cooperation anong milk producers.

S uch cooperation is necessary but what will oe the result? If the
ordinances of a city are injurious to the interests of its local
milk producers, instead of turning cooperative effort toward reduc-
ing the cost of production, toward increasing their efficiency as
agricultural business men, and toward improving the dairy business
in general, the milkmen will be able to successfully boycott the cit
and effectively cut off its milk supply. The argument won't nold
that such a boycott is impossible because the city can bring in its
milk supply from territory hundreds of miles beyond the vicinity of
the cooperating farmers. If the physical characteristics of ilk

do not put a limit on long shipments, economic considerations will,
and in addition, any cooperative system can be directiy proportional

in extent and effectiveness to the determination of the cooperators.
 

Cooneration among farrers is comine very slowly but surel:,

&

the cirection of its effectiveness and mission will be @etermir«:
largely by health commissions. A former cannot dictate to the mor-
ers of an ordinance, if at all, cnly as a citizen within the city
fimits, but he can make sugzestions for the framing of the ordinance.
To accert sugzestions, if they are practical and worthy of consi¢-r-
ation, is a step in the right direction. A health commisston shits
@o even farther and should include among its number one or more rr-
gressive fermers, or representatives chosen by the farmers effect=:
by the Local ordinance. Such should give rice to a sririt of sati:-
faction and then a cooperative spirit for improvement would nec¢s=-
arily result.

On studying the milk question, and in rarticular, considerin<
milk orcinances from the producer's standpoint, I have concluded t! 1
the followirg factors should receive recognition in the ordinary nil?
ordinance governing rilk and cream:

4. Condition of stables in which it is produced.

2 Condition of rlaces and recentacles in which stored.

3. lMetnod of cleaning the utensils used.

4. Condition of cows and of milkers at and durirg milking.

5 Temperature of milk while in milk house and until deliveres

to the consumer.

6. Stage of lactation during which the milk is produced.

7- General health of herd and of each individual cow.

Health of all persons, engeged in the production and subse-

quent handling of milk, and of their respective families.
9. Nature and quality of feed fed to produd ng mimals.
 

 

10. Quality of milk.

ll. Bacterial content with svecial eryphasis on tynes vresent.
12. Care of milk and cream by consumer.

13. Loss of bottles by consuners.

14. Qualifications of inspecta s.

15. Score ecards used by inssectors.

There are otner minor factors which we do not think worthy sc:
Q@iscussion here. The methods of keening the list of city milk de 7-
ers, their licenses, etc., and otner related details, are matters c*
routine work to be cered for by a City Clerk as he sees fit. Tr :-:
are included in many ordinances though not in all cases, as the:
have no bearing on the rilk question.

In considering the kind of score card used by Inspectors 1
would recommend the one known as the Cornell University Dairy fcr:
card. Its superiority over other score cards are: (1) Its questi. -
will bring out the actual conditions of the dairy; (2) The ansus-
mace by Lnepectors are coapiled’ in the form of score by an ex,e rt,
and the wide variations of individual judgment are thereby eld:i:-

ated. The questions are as follows:

Telryman . Date

PD. C. Locention

MO, cows milking In herd Gis. wilk Cans or Bottl-+
Lilk sold to Ticense Wo.

Report by At milking time? Four ,

1. Health of the herd and its rrotection®
Do all cows appear hnealtny?

Are udders sound and free fron sions of @isense®

=—_
ll.

are covs tuvere.wlin testec?

Date of last test By whom

Is the stable well Duilt to protect fron the weather?
Are cows brought in during bad storms?

How many hours are the cows out dail;

Width of stall Length
Is the stall confortadle? Wow are the cows tie?"

Vind and quality of redding

VPrere are cows kept wren sick and at calving tie?

Is the stable well located?

Number and size of windows.

Size of the statle, len,th width heighth
How ventilated

Kinds of feeds used

Are they of good quality and rrarnortl ons?

Source of water for cows

‘wethod of watering.

Cleanliness of the cows and treir surroundings.
Are the cows clenn®? Yow are they cleaned"

Is the hair clipned about the udder?

oh

Is tne udder cleaned tefore miline® Tow? “here

edad

Cc

Zs the stavle free from accuaulation of cobwebs, dirt, and dist
Is the stable white-wasned°?

Kinds and nurber of other animals, if any, in same room with «©
Same, adjacent rooms What orenings betwien?

Is the stavle yrotected from such sources of contamiantign cs

rrivy, etc.
LV.

EFow often is the muiere pornoved Frou
Is the barnyeri free from manure pile? And mad-holee®
Is the ;ustire clean and free fron injurious slants?
And mud-noles?
Is the stable ;rovided with dust-tight ceiling?
and partitione?
Is feecing done before or after milking?

Is the alr free from dust and odors?

Construction and care of the utensils.

Are all utensils such that they can be thoroughly cleaned?
Béethod of washing utensils?

How are the utensils sterilized?

Is the water used for washing utensils pure? Yow do you Kru ®
What is its source?

Is the source protected against contamination?

Eow are utensils cared for after cleaninz?

Is a small-toc pail used for milking?

If so, what etyle and size of opening?

Health of employees and manner of milking.

b-+y

What evidence is there of absence of contazious disexse and
exposure of fanily and employees to disease?

Are the milkers clean personally?

Do the milkers wear clean over-all suits? FEow often
are the over-alls washed?

Do the milkers wash their hands just before milking? Where®

Do milkers have wet hancs when milking?
Are wilkers careful not to dislodve hair and dirt from tne co:
Widle milking?

Is the forenilk discarded?

V. Handling the milk.
How ie the milk cooled?
How soon after milking is the milk cooled?
To what tenrerature?
Is the milk nandled in a room detuched fron the stable?
Wnat kind of floor?
Is the milk room used exclusively for milk, and is it free
from dirt and odors?
At what temperature 1s the milk kept after cooling?

How is milk cared for during transportation to market?

This comprises the list of questions for the inspector to ar-
swer. It 4s readily observed that personal opinions cannot affect
tne answers to the questions at all and that the farmer has the ben-
efit of having his dairy accurately and honestly scaei every time.
The answers, when turned in at the office, are compiled in accordanveé

with the following score:

City of Detroit
Score Card For Production of Sanitary I1ilk
Date Dairy of P. Q.
1. Wealth of Fealth and comforts of the cows Perfect Score cuss
ne herd and their isolation when sick or

and its at calving time 4F
orotec=

tion

» Cleanli-

ness of
the cows
and tnueir
surround-

ings.

Construce
tion and
care of

utensils

. Health of

employees
and manner

of milking

Jocation, lighting and ventilae-
tion of the stable
Food and water

Total

Cows

Stables

Barnyard and pasture

Stable air (freedom from dust and
odors)

Total

Construction of utensils and
their cleaning and sterilizing
Water supply for cleaning and lo-
cation and protection of its
source.
Care of utensils after cleaning
Use of snall top milking pail
Total

Health of employees

Clean over-all milking suits and
milking with clean, dry hands

Quiet milking, attention to cleanli-
ness of tne udder

Total

39
20

100

30
20
20

30
100

40

30

29
100
Prompt and efficient cooling 35
the milk Werdling milk in a sanitary

room and holding it at a low

tenanerature 35

Protection during transport-

ation to market. 30
Total 100
Total of all scores 500
If the total of all scores is And each di- The sanitary
vision is conditions are
469 or above C0 or above Excellent
455 or above CQ or above Good
499 or above 60 or above Medium
Below 400 Or any division
is below 60 Poor

The sanitary conditions are

Scored by

In useing the Cornell University Dairy Score Card a farmer ci.
get a copy of both perts, learn what constitutes perfect under
exch heading, and can then keen an accurate record of his own dairc;
for the purposes of detecting possible errors on the part of the ir-
Brector and use it as a guide for making imvrovements. The score

card put out by the Dairy Division of the Bureau of Ani:+1 Industr:
at Washington covers all points under consideration in a thorough
inspection but it fails to furnish an inspector with any guidance
whatsoever, and, whether he may be honest or not, the farmer may be
under scored because of the wide variation in individual judgment
allowed the inspector.

The application of an ordinance to be the most effective must
be so accomplished that it can gain the good will and cooperative
efforts of the producers to the cause of sanitary milk production.
In this phase of the problem lies the solution of offering something
to the producer as a compensation for his extra labor and necessary
improvements. Such a plan is already in working order in the cit;
of Geneva, N. Y. It was instituted in 1907 and has completely
changed the milk supply of that city. Although the New York State
Agricultural Experiment Station is located in the same city, it was
not connected directly or officially with the new plan.

The new plan consisted in grading the milk and selling it on
a basis of quality. Four grades were recognized and defined brief-
ly as follows.

(1) "Excellent"-- milk drawn in clean barns, from reasonably clean,
tuberculin-tested cows, by clean milkers, into sanitary pails, and
promptly cooled.

(2) "Good"-« from dairies providing a reasonably clean, well cooled,
but not, ordinarily, a tuberculin-tested product.

(3) “"“Medium"-ein the main, dirty milk.

(4) “Ppoor"-eessentially filthy milk.

In addition to the system of grading was the admirable feature of

publicity. This feature was, of course, introduced in successive
steps but in ite final form it protected the health authorities
from legal responsibility for financial losses resulting from the
publication of facts, and it made accessibdle and intelligible to
the largest possible number of people the results of the dairy in-
spection. The best protection against legal action is to conduct th
inspection in such an evidently impartial manner as to obtain tre
support of all parties. The plan has been further explained as fol-
lows;

**The Inspector reported to the Dairy Products Committee. Thi

L$) ]

committee reported to the Board of Health, the report being accepted
and entered in the minutes. This portion of the minutes was publis
ed by the press as a part of the proceedings of the Board."

"In the matter of publicity the three classes, the producers,
the retailers, and the consumers, were considered separately. Lach
producer was furnished with a carbon copy of his official score cara
Each retailer was given the numerical score of the producer whoce
product he was handling. The consumers were reached by the quarter-
ly publication of the standing of each producer, with the name of
the retailer who was distributing the milk. The official score cerd

for each dairy was placed on file with the clerk of th Board,
where it could be easily consulted by any one who was interested."

This plan was introduced with a complete notification of the
all the farmers one year before it was to go into effect. This gave
them an opportunity to put their dairies in shape and raise their
score before it should be published. The first published inspection
gave the following summarized results;

*Bulletin 337, N. y. Agricultural Experiment Station, page Cl.
Grading To. Dairies

Excellent Tone
Good 7
Wediun 28
Poor 3

Total “ISI

Three years later tie nublished report showed a cecidecly tirprove:

cniange:
Excellent 5
Good 34

Total 35

In making their annual contracts with the producers, a dairyin.
ccmpaiy which had been formed for handling the milk supply, incluace
a clause whereby any producer would receive three cents ner quart c-
long as his dairy scored "mediuz," three and one half cents when it
scored “cood," and four cents wien it scored "excellent." The offi-
cial score of the dairy f@ each quarter was to be taken as tne bacis
for making settlenents. The dairies whose nroduct was handled b--
this company mede a marked imvrovenent, while dairies, whose rrocuct
was cared for by a company paying at a flat price, fell in their
scores. The improvenent seemed to indicate that it was more profit-
able to produce clean milk, and that the farmers made an effort t-
produce such milk when method of payment depended unon tine cunlit:

of product. Ultimately, however, the success or failure of this

plen of improving a milk sunply must turn on the extent to which t:
purchasing public transfers its custom in accord with the official
standard of quality. |

The first part of this paper tended to show that the milk or-
dinances are not very much at fault except that in some instances
they are extremely radical. The views which I have expressed as
being from the standpoint of the producer, would undoubtedly be re-
pudiated by most farmers. Then how can these views have any clain
to expressing the farmer's viewpoint? Simply in this reepect; the
vast majority of the farmer class are still asleep to the solution
of the milk question, to a full understanding of its present day
extensiveness and effectiveness, and to the wonderful opportunities
in its future when a master hand shall solve the question and reor-
ganize the system. Some milk producers are wide awake and are far
better acquainted with the milk question than are the majority of
health commissioners and inspectors, but they are comparatively fev.
It is one phase of the milk question from their standpoint which I
have tried to express. .

A book entitled "The Milk Question" by M. J. Rosenau has just
been issued by the press. The author is a member of the faculty of
the Harvard Medical College and has formerly been employed in the
United States Public Health and Marine Service. He is well quali-
fied to discuss the milk question, at least from the scientific
viewpoint, and has done so in a very capable manner in his recent

publication. He has stated the facts both in pictures and print |

 

and has shown justice to all concerned, the farmer, the milk peddler,
the creamery man, the health officer, inspector, and consumer. But
|

the very last sentence of his work falls short of the standard main-
teined in the rest of the book, and it falls stort in its finel a..-
alysis and solution of the milk question. Fe says: "A milk sun; ]1;,
therefore, tiat is botn supervised and pasteurized is the only ¢x‘-
isfactory svlution of the problem." Professor Rosenau has fails: ;
far short of wording the solution of the milk problem in this one :
brief sentence.

In a recent number of the American edition of the “World's Work'
is a lengthy article entitled "The Bacteria of Bad Business." It
deals with a quite thorough investigation of the milk supply of Ro-
chester, N. Y., vy the author, Dr. John R. Williams. He writes thet
"two inevitable conclusions arose clearly from the mass of detail
gained in his investigation:

(1) The fundamental cause of impure milk on the farm is the
uneconomic method of rroduction.

(2) The fundamental cause of impure milk in the city is the
uneconomic method of distribution." He then concludes; "The solu-
tion of the milk vroblen lies, therefore, in the better economic
control of production and distribution." Dr. Williams has correct-
ly solved one phase of the milk question but has beldly advanced it
as the solution of the whole rproblen.

The American Associations of MWedical 21k Commissions thought
tney saw the solution of the milk cuestion in tne Ineffective, ur-
organized, city milk ordinances. Accordingly they proceeded t»
sslve the problem by enacting etrinsent lesislation to control tre
producer in the production and distribution of milk. The colleg::

of agriculture have indirectly attenoted to sclve the question by
teaching the farmers to lower the cost of production by economic,
scientific methods of feeding and caring for their cows, and to in-
crease their productivity by scientific principles of breeding.
These three methods are good and all in the sight direction but they
haven't solved the problen.

Bacteriologists have discovered some very valuable things con-
verning milk, its chemical constituents, its bacterial flora, and its
physical properties. Upon these findings the health commissions
have based their rules for sanitary improvements. They issued their
demands to farmers in terms either too scl entific or too indefinite
to be understood. As a result, improvements have not been made, the
farmers have suffered fines, unjust criticism, and public abuse, for
their excsable ignorance, and the consumers have come to consider
themselves the would-be victims of a plot to sell them filthy, di-
sease-laden, adulterated milk. Evidently bacteriologists have not
succeeded in solving the question.

The way looks dark and dangerous, therefore, for any new theory
for the solution of this difficult question. However, each of the
examples cited have been in the right direction and have contributed
some progress toward the solution of the milk problem. Common sense
would then prompt the combining of all these methods, together with
any other factors which have proved to have an influence on the ques-
tion. A new theory would then call the consumer to realize and share
his part of the burden of the milk question by observing the rights
of the producer and paying a just price for milk; would then empha-
size economic control of production and distribution; would emphasize

the teachings of the egricultural colleges; would urge health commis-
sions to teach and show the farmers the “why" of legislation and
sanitary principles; would wake the farmer to realize his position,
take advantage of his opportunities, and bring his business up wie?-
it belongs, namely in the lead of all industries.

John Spargo has worded the problem and its solution aptly:
"rarents cannot accomplish the task alone and unaided; physicians
cannot do it; farmers and milk dealers cannot do it; it cannot be
done by the governing bodies of our cities and states, or of the
nation itself. But all these forces combined, earnestly and since:~-
ly working together, can do it, and so bring about the tri-

umph of life over death, of health over disease,®
OT
3 HI 03083 0255