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BLEACHING OF FLOUR.

BY E. F. LADD, CHEMIST AND FOOD COMMISSIONER FOR NORTH DAKOTA.

I take it that among food commissioners, health officers and sanitarians, it may be considered almost as an axiomatic principle that the addition of any unnecessary chemical to a food or beverage shall not be deemed as justifiable or lawful in any product until it has been clearly and satisfactorily proven that the chemical or drug as found in the food, should it there remain, is entirely harmless, that it does not injure or in any way lessen the food value and that fraud in its use is not thereby abetted. Thus the burden of proof falls as it should upon those who would add foreign and unessential chemicals of whatsoever kind to any article of food or beverage intended for general consumption of the people at large and not upon those whose duty it is to see that the laws are enforced.

In other words is it permissable to use either in foods or beverages products the effect of which upon the system are not well understood? Products which if harmful, used in continuous but minute quantities, can only produce injury after a long period of time. Are we justified in permitting the use of any unnecessary chemical product in food until it has been clearly demonstrated to the satisfaction of the best experts and to the satisfaction of the people at large that the use of such product is absolutely harmless? Has any manufacturer or producer of foods either a legal or a moral right to introduce unbeknown to the consuming public

any active chemical into a food until it has been proven perfectly harmless, or until it has been satisfactorily demonstrated that it in no way injures its food values?

Are we not often enough afflicted with impaired digestion and other ailments, the cause for which are not well understood, without permitting manufacturers or any one else for that matter, to add even the minutest trace of any contaminating product of uncertain physiological action? What good comes to the consumer from permitting the use of oxides of nitrogen or of nitrogen absorption, substitution or addition products or of nitrites in our food?

Anilin butter color was said to be harmless, but it has caused the death of at least two children in North Dakota, and we do not know to what extent it is undermining the health of our people, since it is used in such minute quantities and in only one article of food. Shall we now permit the introduction even in minute quantities into a product so generally employed as a basis of food as is flour, of a chemical wholly unnecessary in the manufacture and concerning the ultimate effect upon the health of which, we know so little?

Winton says: "The chemical bleaching of flour is a matter of grave importance, because the treatment may affect the quality and wholesomeness of the product."

Dr. Wiley says: "At the present time flour is extensively bleached for the purpose of making an inferior article resemble a superior one."

A committee of the Paris Association of Bakers made a study of the subject of bleaching and from the commercial

tests usually employed by bakers concluded that, although the appearance of the flour was improved by the bleaching, the flour itself and the bread made from it had suffered in flavor, and this fact alone was sufficient to condemn the process. They further concluded that it is inadvisable to introduce into a natural product par excellence, chemicals which, without adding to its real value, may, on long continued use, prove to be harmful.

The question of the bleaching of flour is therefore one of vital importance because it affects all people since we are dealing with the most important food product used by man, and it is advisable that there be made as complete an investigation as possible of all features of the subject of bleaching. The North Dakota Experimental Station has been engaged for some time in such an investigation, especially so with regard to the chemical features. Many arguments and statements have been put forth in defense of the process, none of which seems to the writer to possess sufficient merit to warrant the passing of our final decision upon this data and the argument presented for consideration. For example, the argument that since saliva contains sometimes nitrites (whether this be normal or abnormal has not been shown), therefore the further addition of nitrites to food can do no harm, is as groundless as would be the statement that since saliva contains potassium sulphocyanide, therefore this poisonous product should be added to our food. Its use as a medicine might be proper but the presence of either in saliva is no real argument for their use as a food.

Hydrochloric acid is a normal constituent of gastric fluids but we do not find physicians recommending its use as a beverage or food even in minute quantities.

Bleaching as investigated by the author has been produced either by the decomposition of HNO3 by an electric current, or by the discharge through the air of an electric current causing the union of the nitrogen and oxygen of the air. All agree that the same agent does the bleaching no matter which method is employed, and the principal bleaching agent is the peroxide of nitrogen. This leads us therefore first to consider,

METHODS OF DETECTING BLEACHED FLOURS.

First-Griess method as adapted from water analysis is as follows: Shake up say 50 grams of flour with water for 15 minutes in a flask, filter and treat the filtrate for nitrites as in water analysis. The pink coloration gives some idea of the extent of bleaching. The only objection to this method is its delicacy. Unbleached flour stored along side of bleached flours gives a trace of nitrites, but the careful chemist can distinguish by this method bleached from unbleached flours. The results by this method, if determined quantitatively are low, since it is only the soluble nitrous acid (?) or nitrites (?) that are estimated and those that are absorbed (?) by the fat or combined in the fat and gluten are not estimated by this method of determination. This is clearly indicated further on.

Second-Fleurents method (somewhat modified). The fat is extracted from 50 grams of fiour by ether, filtered, dried for two hours, taken up with petroleum ether and this evaporated to dryness. Now add 2 to 3 c. c. of amyl acetate until the fat is dissolved, then add about 5 c. c. of alcoholic potash (10 grams KOH to the liter). If the flour has been bleached the resulting solution has an orange or reddish tint. If unbleached the solution has a yellow color.

Precaution should be taken to have an aldehyde free alcohol and this was prepared by the method of Dunlap and Bailey (American Journal Chemical Society, March, 1906), and is as follows:

One liter of alcohol is taken and to this is added two

grams of KOH. Of silver nitrate 1⁄2 gram is dissolved in a small quantity of alcohol, and this gradually added to the alcoholic KOH in a cylinder. Shake thoroughly and allow to stand for 12 hours then decant off the alcohol and distill. The distillate is aldehyde free alcohol.

This method has been found to be very accurate and one may when working with care detect even the slightest bleaching.

Unbleached flours stored along side of bleached flours do not show a trace of orange coloration thus making the method more satisfactory than the proceeding one for the detection of bleached flour.

Since the bleaching of flour in a large measure so far as apparent improvement in appearance is concerned, consists in the bleaching of the strongly yellow colored oil contained in the flour in order to ascertain, if possible, what changes the oil had undergone in the bleaching process, a number of oils were extracted from bleached and unbleached flours and

these oils then examined. In each case about 200 grams of flour were thoroughly extracted with ether, the ether distilled off and the residue taken up in redistilled petroleum ether, the solution carefully filtered, and the petroleum ether thoroughly evaporated off. The yield of oil is usually about two cubic centimeters.

Wheat Flour Oil No. I was obtained from a "clear" unbleached flour which had been in the station laboratory nine months.

58.0° 49.5°

Refractometer reading at 25° C.:
Refractometer reading at 40° C.
Iodine number (Hanus Mod.) = 101.2°
Odor, wholesome, not at all rancid.

The aqueous extract from the flour tested with naphthylamine for nitrites gave negative results.

Wheat Flour Oil No. 2 was obtained from the same flour as No. 1, but in this case the flour had been well bleached. It had stood the same length of time in the laboratory (9 months) after bleaching.

Refractometer reading at 25° C. =76.0°
Refractometer reading at 40° C. = 70.0°
Iodine number

=

= 84.1°

Odor, peculiar, pungent, rancid, the oil being stringy and glue-like.

Test with naphthylamine on the flour indicated nitrites present in considerable quantity.

These two oils were then examined for the presence of combined nitrogen. A piece of well cleaned sodium was strongly heated in an ignition tube and three drops of the wheat flour oil was then allowed to fall upon the partly vaporized sodium. When cool the contents of the tube was treated first with a little alcohol and afterwards with water. This solution was then filtered, treated with a few drops of sodium hydroxide solution and of ferrous sulphate solution, and then boiled for a minute or two. Just enough of dilute hydrochloric acid was then added to dissolve the precipitate, and finally was added a drop or two of ferric chloride solution. The presence of nitrogen is indicated by the formation of a precipitate of Prussian blue, which if scanty may remain for a considerable time in suspension giving a greenish blue color to the solution.

The oil from the unbleached flour gave no trace of combined nitrogen, while the oil from the bleached flour gave a copious precipitate of Prussian blue, indicating the presence of a considerable quantity of combined nitrogen in the oil. It has been claimed by the advocates of bleaching that it simply ripens the flour, in exactly the same manner as ageing the flour, by allowing it to stand one to four months before being consumed. In other words it merely hastens nature's processes. If this be true the above oils should have had closely the same refractometer readings and closely the same iodine numbers. The experiment further shows that the nitrogen is not simply absorbed as has often been claimed but is in combination.

Wheat Flour Oil No. 3 was obtained from a "first patent" unbleached flour which had been put up in an air tight glass jar as soon as received in the laboratory and had been kept in that manner for a month.

Refractometer reading at 25° C. = 80.0'
Refractometer reading at 40° C. 78.0°
Iodine number
= 102.9°

Odor, characteristic fresh flour odor. The flour gave no reaction for nitrous acid or nitrites with naphthylamine hydrochloride.

Test for combined nitrogen with metallic sodium gave no trace of Prussian blue.

Wheat Flour Oil No. 4 was obtained from the same flour as No. 3, but the bag was allowed to remain in contact with some bags of bleached flour in a large zinc lined box for one month.

Refractometer reading at 25° C. = 88.0°
Refractometer reading at 40° C. 82.0°
Iodine number
= 101.8°

The flour reacted strongly for nitrites with naphthylamine. The oil tested for nitrogen with metallic sodium gave a decided precipitate of Prussian blue.

A loaf of bread of standard size was made from a bleached flour in the same way that test loaves are usually prepared, but without the addition of any foreign fat. The loaf was dried, ground to a fine meal and extracted with ether as described above, the oil obtained from it was of greater consistency than the oils obtained from the flour. On being tested for combined nitrogen it was found to be present without question, but in much less quantity than in the above flour oils.

The oil was extracted from several flours which were known to have been bleached and in each case the sodium test indicated the presence of combined nitrogen which would seem to show that the bleaching of flour with chemicals is distinctly different from the natural ageing of flour and that the presence of nitrogen in the oil obtained from bleached flour may be made to serve as a test for the detection of bleached flour as indicated above.

It is possible that flour bleached by other methods than those with which the author is familiar may not respond to this test, but it is certainly more reliable than the naphthylamine test, or the difference in color of the soaps produced from the extracted oil as described by the French chemist Fleurent.

EFFECT OF BLEACHING ON FLOUR AND ON BREAD. Flour stored in well ventilated rooms or exposed to sunlight undergoes bleaching to a certain extent. Fat extracted from unbleached flour on exposure to sunlight undergoes a certain amount of bleaching, but in this case the action is entirely different from the artificial bleaching. Fats and flours which have been bleached in the sunlight do not react to Fleurent's test for bleaching; neither do they give reaction for the presence of nitrites by the Griess method, nor do they show in the fat combined nitrogen. Flours kept in the laboratory but away from flours that had been bleached gave none of these reactions at the end of one year, but did show the appearance of bleaching. That the process of bleaching gives identical results, therefore, with that of "ageing" of flour is not true; the only benefit the honest miller can claim, if it can be called a benefit, for bleaching is the fact that the product is made whiter.

Bleaching results in injury to the gluten and therefore in injury to the bread. That the gluten is injured by the process of bleaching may be clearly shown in a study of its expansive properties. If the gluten from like quantities of bleached and unbleached flour be washed out and baked in a Foster's tester we obtain the following results:

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Wt. of Wet Gluten. Expansion. Gluten unbleached..... .7.99 grams 3 inches Gluten bleached.. .4.99 grams 13/8 inches The gluten in the bleached product was stringy, very difficult to wash out and possessed the characteristic smell of modern four where the bleacher is used. Bread and flour produced by this bleaching was very inferior. It had passed the so-called improving stage, the flour was dark and the bread gray. This condition was similar to not a few samples of flour that have been purchased in the open market and results whenever bleaching machinery has been renovated or the miller is treating his flame too strong.

During the past year many complaints have come to the writer from parties who have been using flour of this type, overbleached, and in not a few instances, housewives have found it necessary to change the brand of flour, all due to the effect of bleaching. Of course the millers do not desire this kind of flour; nevertheless when the process is not kept fully under control such results are secured. The last

experiments seem to indicate the oxidizing effect of the oxide of nitrogen on the gluten and the experiments indicate that there is a union between the nitrogen compound and the gluten itself.

On washing out the gluten from overbleached flour it seems that all nitrogen gases or nitrites absorbed in the flour itself would be washed away. If the washed gluten be tested in the ordinary way by Griess method for nitrites there is no reaction, but if the gluten be allowed to remain in the testing agent for a considerable length of time there may appear a slight coloration. If the same gluten be washed with alcohol to separate the gliadin and this alcoholic solution tested for nitrites we shall get a strong reaction. Carefully conducted experiments with the reagents are negative as are also experiments made with unbleached flour. thus indicating the probability of combination between the nitrogen compound and the gluten itself.

That the nitrogen is not eliminated in baking is shown in the following cases in bread made in the usual way with yeast:

Sample No. 1, bleached slightly-Reacts for nitrites. Sample No. 2, bleached strongly-Reacts strongly for nitrites. Sample No. 3, bleached for trade-Reacts for nitrites. Sample No. 4, unbleached-No reaction for nitrites. Sample No. 5, unbleached-No reaction for nitrites. Sample No. 6, unbleached-No reaction for nitrites. The oven used in baking these breads was a carefully constructed gas oven so arranged that there was small, if any, likelihood of gases being absorbed by the bread or even entering the oven. It has been claimed on the one hand that by baking all of the oxides of nitrogen reacting as nitrites are driven off and that the bread will show no reaction and the same authorities assert that if unbleached bread be baked in a gas oven nitrogen products are absorbed and the bread will react for nitrites, to say the least a rather strange occurrence. It has further been asserted that the oxides of nitrogen are simply absorbed in the moisture and therefore easily driven off on heating. That this is not true is fully indicated from the fact that when flour is heated in an oven at the baking temperature and all moisture is driven off there yet remains nitrogen products which give a strong reaction for nitrites. It is further clearly demonstrated by the experiments which we have already pointed out, that some of the nitrogen was in combination with the fat, also in apparent combination in the gluten. From our own experiments we should say, therefore, that the nitrogen compounds exist in the flour in several forms, absorbed as a gas, taken up by the moisture and forming nitrites with bases when such are present, that it enters into combination directly with the gluten itself and combines with the fat to form a tolerably stable compound which changes entirely many of the chemical properties of the fat. The extent of bleaching will determine to a considerable extent the combination.

Quantitatively we have recovered from 3 to 1⁄2 of the amount of nitrites in the bread that was originally in the flour. Thus far we have dealt only with the question of breads made by the usual process, using yeast as a leavening agent. Our experiments on the other hand indicate that where baking powder is used and biscuits, rolls, and like products are baked that there is a breaking up or at least a disappearance of the nitrites and this fact probably accounts for some of the conflicting statements made by different investigators. The conditions and resulting products are entirely different in the case of bread made with yeast and that made by the use of baking powders and the great majority of bread is now made with the use of yeast as a leavening agent.

LOW GRADE FLOUR ADDED TO PATENTS.

A series of experiments were carried out to indicate the amount of low grade flour that could be added to patent flour and "improved." It has been stated that low grade flour cannot be "improved" by bleaching. We have found that bakers' grade can be improved, but not to the same extent as are the better grades. (This is clearly illustrated in the slides which are exhibited.) While macaroni wheat is not inferior to other wheat in our own estimation, by many it is considered to be inferior and is sold at a much lower figure, often from 10 to 20 per cent lower. Macaroni wheat flour is capable of being bleached as will be indicated by the several sides. To a patent 10 per cent of bakers' was added and then bleached and there was secured a whiter product than the original patent. This made a loaf that was whiter than the original patent, but somewhat smaller in size. These facts are indicated in the following table, where the same amount of flour was used in each case:

BREAD FROM

MACARONI FLOUR AND BLEACHED.

UNBLEACHED

It will thus be seen that where a loss in reaction for nitrites has taken place there has been a gain for nitrates indicating the oxidation of nitrites to nitrates. A similar experiment was then made with a sample of commercial flour slightly bleached with results as follows:

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Patent, plus 10 per cent macaroni. Patent, plus 20 per cent macaroni.

Size of Loaf. 194x24 inches

66

+6

19 x24 19 X23%

"From these experiments it would seem that the claim of the manufacturers of bleachers that the patent flour can be increased from 10 to 20 per cent is true, or, in other words, that low grade flours can be added to the patent or a cheaper product substituted for a dearer one.

"It is a well known fact, and admitted by honest millers, that they do bleach their 'clear' grades. One of the best known mills in North Dakota has installed two bleachers, one for the patent and the other for the clear. This would indicate well that not only the lower grades are susceptible of "improvement" by bleaching, but further that such is the common practice among millers employing the bleaching device. These are the only two grades of flour produced in that mill. Another North Dakota mill recently received an order for fourteen carloads of clear flour all to be bleached.

The only reason that bleachers are used, it seems to me, is because by this method they can increase the amount of patent, improve the color and lead the public to believe that the product is the well known white flour. Otherwise how could millers install and operate an expensive piece of machinery of this kind for bleaching flour and still sell their product at a lower price than can millers who are producing patent without bleaching. If substitution is not permissible in other products, should it be tolerated in the flour industry?

In order to further determine to what extent changes in the character of the nitrogen take place in the baking of bread a series of experiments were planned with biscuits made with baking powder and with bread produced by means of yeast. In each case samples were baked in a gas oven and in a range. The first samples were with flour over

bleached and resulted as follows:

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Moderate reaction

All products used in the preparation of the bread in the experiments above indicated were carefully tested and gave negative results for the presence of either nitrites or nitrates and negative results were secured in all samples of bread produced from unbleached flour.

It would thus seem from the above experiment that in cases where nitrites are not found in bread produced from bleached flour of the type with which we have worked the fact is due to the oxidation of nitrites to nitrates which are then present as such in the bread, and this oxidation or change is more marked and pronounced in the case of small loaves where baking powder or other chemicals are used as a leavening agent. It would therefore be erroneous to assume as some have done that the oxides of nitrogen or nitrites in the process of baking are volatilized.

Experiments are now projected to determine whether the nitrogen compounds in combination with the fat and the gliadin, but not in the form of nitrites, are also set free or changed in baking powder biscuits, rolls, etc., but the experiments are not yet completed.

In conclusion we should say that in the bleaching of flour: First-That bleaching results from the action of the oxides of nitrogen upon the flour and to a considerable extent in its action upon the fat.

Second-That the absorbed nitrogen will be found (a) as addition or substitution products in the fat; (b) in combination with the gliadin of the gluten; (c) as nitrites resulting from combination with bases already present in the bread; (d) as absorbed gas; (e) in some forms of bread, especially those made with chemicals as baking powder, the products will be oxidized to nitrates.

Third-That the gluten of the flour is always injured by bleaching, the extent of the injury depending upon the degree of bleaching.

Fourth-That bleaching is not an essential or desirable adjunct of the milling process.

Fifth-That all classes of flour are susceptible of being bleached and are bleached in many mills and where formerly many grades of flour were produced some of these mills now produce but two grades and all are bleached.

Sixth-The process as now employed is, in its general use, a fraud pure and simple and permits of the substitution of a cheaper product for a higher priced one.

Seventh-That the producer of the wheat is not being benefited by the process, neither is the consumer.

Eighth-That it injures the flour whenever treated slightly and the injury is proportionally greater as the product is overbleached.

Ninth-It forces the honest mill to either put in a bleacher or go out of business, for the natural characteristic of the flour is destroyed and he cannot compete with his competitor who bleaches and substitutes and sells at a less price.

Tenth-It would seem to be a dangerous practice to treat such a universal food product with such a dangerous chemical, the physiological effects of which in the bread are as yet not well known.

Eleventh-Flour is very susceptible to contamination and readily absorbs odors and gases and when stored in the vicinity of bleached flour it readily takes up the oxides of nitrogen.

Twelfth-Flour exposed for more than one year in open rooms does not absorb from the uncontaminated atmosphere either nitrites or the oxides of nitrogen in detectable quantities.

Thirteenth-The quality of the bread is always injured and the characteristic and satisfying flavor of the bread is lessened and in overbleached products largely destroyed.

Fourteenth-Is one justified in adding a dangerous chemical product to a food until it has been clearly and satisfactorily demonstrated that the resulting product is entirely harmless or that it does not in any way lessen the food value of the product.

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LIKE SUBSTANCES. By Prof. J. H. Shepard, Chemist South Dakota Food and and Dairy Commission.

What are "like substances"? At the first blush the question seems easy. Everybody knows what is meant by like substances. Ask anybody. He can tell you. But unfortunately every answer will be different. In common every day parlance the two words are used loosely, comprehensively, lavishly. They are applied to things resembling each other all the way from the most remote resemblance to complete identity. And so while everybody can define "like substances" the definition will originate from every different mental concepts. In a hazy sort of a way everybody realizes the unsatisfactory status of the expression, hence the attempt to differentiate by the use of such expression as "as like as two peas," etc.

In short, the word "like" as used for sake of comparison is overworked.

LIKE SUBSTANCES AND FOOD LAWS.

A little more thought on the part of the author of the clause defining a "Blend" as a "mixture of like substances" should have warned him that he was dealing with a very uncertain and to him a dangerous weapon. If the expression "like substances" is so indefinite in its common every day use, what would it be liable to mean when incorporated in a pure food law? This brings us fairly to the question that has so profoundly agitated manufacturers, dealers, consumers, lawyers, and pure food officials during the past year. Even the president of the United States of America has not escaped. It was just like going back to preparatory school again in order to take a post graduate course in etymology.

PROF. J. H. SHEPARD.

But it was a very grim and determined class of boys who were learning and fixing the meaning of "like substances." Little resemblance did they have to the joyous, care free youth who are to-day studying their spelling books and dictionaries. Great interests were involved and it was necessary that the definition be given and fixed correctly at the very outset. I presume it would be safe to say that no other two words in the English language ever cost so much of thought and treasure to have their exact definition fixed. But I believe that the far-reaching and beneficial results that will follow in the commerce and manufacture of food, beverage and drug products will fully justify the labor and expense. There is scarcely one of these products that will not be more or less affected. It is true that at the present time, while the dust and fog, and confusion of conflict still fill the air and obscure clear vision, each manufacturer sees only the bearing upon his own particular product. And, naturally enough, he gives voice to his own griefs and fears. Meanwhile the public hears only the complaints of those who are most loudly and actively reciting their woes from the house tops. But to the pure food official the situation is very different. He hears all sides of all stories and while the official year is still young, enough has already developed to indicate the profound modifications that are certain to come in the marketing and labeling of very many articles used for human dietaries, beverages and medicines. But perhaps a clearer understanding of the situation may be had by considering a few specific examples.

WHISKY AND "LIKE SUBSTANCES." Of all the interests most actively engaged in defining "like substances" the so-called rectified whisky interests, taking the manufacturer's stand point, stand forth without a peer. This interest representing enormous capital and vested rights, seems to have been more alarmed, and unnecessarily alarmed as I believe, concerning the ruling declaring that whisky and alcohol are not "like substances." Their particular grievance was that this ruling would deprive them of the use of the word "blend" as applied to mixture of whisky and netural spirits or alcohol.

In lieu thereof they were assigned the word "compound" which failed to satisfy them in the least degree. In the first place many of these people have been in business for more than a generation and have grown accustomed to the word "blend" and have a sentimental regard for it. Concerning this sentimental regard it is not to be argued. A man has a right to love and esteem his own wife, his horse, his watch and his own business methods. Of course if any man's business methods work a damage to his neighbor, he is subject to restraint and must relinquish the offending practice that invades or imperils the inherent rights of his neighbor. In the second place very many of these people were afraid that if their goods should appear with the word "compound" on the label that great and irretrievable injury would result to their financial interests. Someway they conceived a violent antipathy to the word "compound" just as if the word had a vicious or sinister meaning attached to it which it has not. It is a good, wholesome word, doing honorable duty in our pharmacopoeia to-day as it has done for generations. Then again they were afraid that if people actually knew just what is in the whisky they had been accustomed to drink or knew how it was made they would refuse to buy.

Or in other words if the goods were labeled a "compound" instead of a "blend" the consumer would discriminate against them. I do not believe this ground is tenable. I do not believe that the average consumer would care a fig whether his favorite brand of whisky were labeled a "blend" or a "compound." Consequently I cannot see where the compounder's fears are well grounded. But, it may be objected, "The public will become educated." Well, perhaps so. But if the educators have no easier time of it than the average college professor does in instilling all the nice shades of distinction attaching to scientific terms into the minds of average college students, my sympathies do certainly go out to the educators.

During the various hearings that were given to this subject, I have been assured that an overwhelming mass of testimony was submitted by certain so-called experts and by others who were not so expert trying to prove that whisky is alcohol and that alcohol is whisky, all of which every one knows to be untrue. Even the most ignorant navvy on the railroad grade would not accept a glass of alcohol in lieu of a glass of whisky that he had just paid for.

But when words and facts come before courts and judges for a hearing sometimes strange testimony is given, strange decisions are reached, and strange reasons given for the verdict rendered.

I do not care at this time to enter into any discussion as to why whisky and alcohol are not like substances, since I have expressed my views at length in my report to the secretary of agriculture. Suffice it to say that they were declared unlike since alcohol is lacking in those congeneric substances which impart flavor, aroma and taste to whisky thus placing whisky in a class by itself. By some these substances which accompany the alcohol and water in whisky have been called impurities. But this view is manifestly wrong since without these substances there is no whisky. Then again alcohol is a cheaper substance than whisky.

Now, it is the aim of all pure food legislation to protect the health of the consumer, and also to prevent him from being defrauded. Hence it seems that substances to be "like" in the meaning of the law must be very nearly equal value as well as to belong to the same highly specialized class. It is true that alcohol and whisky are like in many ways commonly speaking. They are both liquids; they both consist largely of alcohol and water, they both contain practically the same congeneric substances only differing in amount, the alcohol carrying less than the whisky, but with this difference that the secondary products in the alcohol are in a raw and uncombined condition; they are both capable of producing intoxication and finally their food value must be very nearly equal. But in spite of all these similarities alcohol and whisky have been declared unlike and as I believe very

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