of sulphur dioxid to 350 milligrams per liter. Wines have been offered for import, for example, containing much more than this amount of total sulphur dioxid, but there is every reason to believe that this excessive amount is due to lack of careful control. As the sulphured wine ages the sulphur dioxid, as such, gradually disappears, either by combination with the constituents of the wine or by oxidation. "A limit must likewise be placed on the free sulphur dioxid. An examination of a large number of sauternes has shown that the amount of free sulphur dioxid which they contain is needlessly high; in some instances this amount has exceeded 200 milligrams per liter, and about 20 percent of all the wines examined exceeded the limit set by this decision. If the amount of free sulphur dioxid in wines is placed at 70 milligrams per liter it is certain that the wines prepared for consumption can be produced in a sound condition, not only well within the maximum set for the free sulphur dioxid but for the total as well. It is absolutely necessary to restrict in some manner the sulphur dioxid in cases in which it is used under conditions such that it may enter into combination with acetaldehyde, sugars, etc., present in food products, and it is believed that under the restrictions suggested the public will be protected from products unduly sulphured during the period which must elapse before experimental evidence can be obtained as to whether a total restriction in the use of sulphur dioxid under all the conditions mentioned is necessary on account of the toxic properties possessed by sulphur dioxid in the combined form."" § 233. Label to Show Preservatives. "The decision' provides that the label of each package of preserved foods, or of foods containing benzoate of soda or benzoic acid, shall bear a statement that the food is preserved with sulphur dioxid or with sodium benzoate, or benzoic acid, as the case may be, and the label must not bear a serial number assigned to any guaranty filed with the De 1 Memorandum to F. I. D. 76. 1 Memorandum to F. I. D. 76. partment of Agriculture or any statement that the article is guaranteed to conform to the Food and Drugs Act. "The necessity for these requirements is obvious. Where preservatives are used the labels should inform the consumers of that fact, and it is the opinion of the board that the preserved food does not comply with the law and that it is unfair to the consumer to allow a statement to be made upon the label that the preserved food is guaranteed under the Food and Drugs Act, for the consumer may interpret this statement as to a guaranty that the food is pure.” § 234. List of Dyes Permitted. "The following list of dyes has been recommended in the decision for use in foods and foodstuffs, pending further investigation and announcement of its results: Red Shades: 107. Amaranth. 56. Ponceau 3 R. 517. Erythrosin. Orange shades: 85. Orange 1. Yellow shades: 4. Naphthol yellow S. Green shades: 435. Light green S. F. yellowish. Blue shades: 692. Indigo disulfoacid. "The decision further states that these coal tar dyes must be made specifically for use in foods and bear a guarantee from the manufacturer that they are free from subsidiary products and represent the actual compound whose name they bear. "The following statement is necessary in order to illustrate the principles guiding the Department of Agriculture in framing this portion of the decision: "An extended study of the large number of so-called coal 2 Memorandum to F. I. D. 76. tar dyes which are now in use for the coloring of foods and foodstuffs has been necessary to arrive at a conclusion concerning the restriction, if any, which may be placed on their use, and the department acknowledges the very efficient aid rendered during the course of this study by Dr. Bernhard C. Hesse, of New York City. Dr. Hesse has had an extended experience in this subject through his long association with the leading dyestuff manufacturers in Germany. Since severing his connection with them he has given his time largely to expert work along this line. "The literature on the subject is very unsatisfactory as to what coal tar products are used, and it is not to be depended upon, because of the equivocal nature of the terminology employed. It is impossible to reduce this terminology to an unequivocal and definite basis for the great majority of such coal tar colors. "It was impracticable to go to all those in the United States who use coal tar dyes in food products and obtain specimens of the coal tar colors so used. This is true not only because of the large number of such users and their wide geographical distribution, but also because of the reluctance which would undoubtedly be encountered among many such users to disclose the nature of the products employed by them. "The sources of coal tar materials are limited in number, however. By reference to the book entitled "A Systematic Survey of the Organic Coloring Matters," by Arthur G. Green, published in 1904, on pages 9 and 10 thereof, it will be seen that there are thirty-seven different concerns in the world engaged in the manufacture of coal tar materials. Therefore a canvass of these sources for such coal tar coloring matters as, in their judgment, or in their business practice, they regard as proper for use in food products, seemed the best mode of obtaining a knowledge of the field of the coal tar colors here in question. "Communication was had, therefore, with thirteen manufacturers of coal tar colors in an endeavor to obtain from them a list of such coal tar colors as, in their judgment or business practice, were deemed suitable for use in food products. When this cooperation was established, request was also made for information as to the composition of the coal tar samples submitted, and in order to avoid confusion samples were to be identified by reference to the 'Systematic Survey of the Organic Coloring Matters,' by Green, in which each coal tar color has its own number. This information is necessary to reduce the terminology to a common and unequivocal basis. The thirteen manufacturers, or their accredited agents, with whom communication was held probably represent from 85 to 90 percent of the total dyestuff output of the world. "In order to make provision for the twenty-four makers on the list in the Green tables, and not included in the thirteen makers consulted, a request for samples was made from two New York City houses, who themselves import coal tar colors from sources other than the above, for use in food products. Their products must fairly represent any output not represented by the thirteen makers above mentioned. "The question of the choice of dyes for the coloring of foodstuffs has been decided on the basis of those dyes which have been submitted by the manufacturers or their accredited agents, but it was impossible to consider any dyes when the manufacturer or the accredited selling agent was unwilling to state unequivocally what the dyes submitted were, so that they could be identified chemically. "When those interested in placing dyestuffs on the market for the coloring of food have shown unwillingness to give information of this kind, as to what they sell, and by thus selling, recommend, the burden of proof as to the harmlessness of such dyes lies with them, and until such proofs are adduced, the use of such dyes should be inhibited. "With this knowledge of the specific nature of the dyes recommended, the department has made a study of those concerning which there has been the greatest unanimity of opinion among the manufacturers or their agents as to their fitness; and in the cases where such dyes have been studied as to their physiological action, and the reports have been favorable, they have been included in the tentative list proposed in the food inspection decision herewith. "This tentative list of dyes includes a wide range of colors sufficient for all legitimate purposes. Among them are none which are patented, so that their manufacture is open to all interested in the dye industry. "One point must be particularly emphasized regarding the use of these dyes, namely, the need for the manufacturer's guarantee of purity. It is the manufacturer above all who knows the exact nature of his dyestuffs, and if he is willing to sell his colors for use in food stuffs he should be willing to guarantee that the dyes really are what they are represented to be, that they are not mixtures, and that they do not contain harmful impurities. "In order to further minimize the possibility of harmful impurities existing in these dyes it has been thought necessary to require a further examination by competent experts, a certificate from whom is necessary, stating that the dyes in question are what they are represented to be."" § 235. Entry of Vegetables Greened with Copper Salts. "The decision [F. I. D. 76] states: The question of the entry into the United States of vegetables greened with copper salts has not been finally determined. Pending the determination and decision of this matter by the Secretary of Agriculture all vegetables greened with copper salts which do not contain an excessive amount of copper will be admitted to entry if the label bears a statement that sulphate of copper or other copper salts have been used.' The greening of vegetables with copper sulphate is practiced to a large extent in some foreign countries, and vegetables so treated are imported into the United States. Before the passage of the Food and Drugs Act the Department of Agriculture, under authority of the yearly appropriation acts, controlled the import of foods. It has been the practice to admit vegetables which did not contain an excessive quantity of copper salts if the artificial color were 1 Memorandum to F. I. D. 76. |