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41. The Merchandise Marks Act, 1926.-This Act was also under consideration in the form of the Bill.

The local authority under the Act is the local authority under the Food and Drugs Acts, and the officers for the enforcement of the Act may be the officers under these Acts, if they are authorised by their local authority to enforce the Merchandise Marks Act, 1926.

The Act authorises the making of Orders requiring an indication of the origin of imported goods to be marked on them. This applies to food as well as to other articles.

CHAPTER XIII.

THE HANDLING AND STORAGE OF FOOD.

1. Improvements in Shops and Stores in Recent Years.-The butchers' shops in Scotland, without exception, are enclosed, and no trace of the ancient and open booth system remains. The great majority of butchers' shops, indeed, have plate-glass windows, and present a light and clean appearance. The grocers are justly proud of the standard of structure, cleanliness and daily care which they have set themselves to attain in the last generation. The Federation of Grocers' Associations in Scotland are now pressing strongly for a system of registration and inspection, in order to maintain the standards of suitability in the grocery trade which, they say, they have built up by forethought, by a great deal of expenditure, and by the education of their members. This fact is a sidelight on the common observation that it is the Legislature and the official Departments that are anxious to increase inspection and inspectors.

The large food factories find it to their advantage to keep their premises clean, to use a good quality of materials, and to preserve them from deterioration; and there are bakers who take pride in the fact that there is not a rat nor a mouse nor a maggot nor a beetle in or about their premises.

It is well to bear these things in mind when the following observations are read. These observations have been drawn from the whole of Scotland, and have their own value. They are not to be taken, however, as reflecting on the generally high standard of food production and preparation maintained by the majority of persons in the various food trades.

2. Special information requested.-The factories, shops, stores and other premises where food is manufactured, prepared, stored or sold ought to be kept in as cleanly a condition as possible, and the desirability of an extension of the powers of local authorities has been represented to the Board by outside bodies from time to time. These representations have received careful consideration. It was considered inadvisable, however, to advocate any definite line of policy unless and until full information was available in regard to the nature and extent of existing abuses or defects in connection with the food supply. Accordingly in prescribing the information to be included by medical officers of health and sanitary inspectors in their annual reports for 1925, there was included the following paragraph, which had hitherto appeared only in the requirements made of the medical officer of health :

"Observations on food inspection, unsound food, and the sanitary condition of premises where foods are manufactured, prepared, stored or exposed for sale, indicating any important respects in which powers have been found inadequate for dealing with insanitary conditions at such places."

Medical officers of health and sanitary inspectors are the officials most closely concerned with the supervision of the food supply, and the evidence and suggestions which they have submitted in response to the above request are therefore of value in any further consideration of the position. In the following paragraphs the results of the enquiry are classified under various main headings, and dealt with at length. It may be noted, however, that a few items mentioned are taken from statements made at the annual conference of the Royal Sanitary Association in 1925, and at an interview on 3rd November, 1925, with representatives of the Association.

3. Places where Food is manufactured or prepared: (a) Bakehouses. As bread is one of the most important articles of diet, special attention has been paid in a number of reports to the conditions in which it is manufactured. The first point to which attention was directed was the method of storing flour. In some cases it was found to be stored in the bakehouse itself. The result is that the part of the bakehouse where the sacks stand cannot be regularly cleaned, and with dust and dirt accumulating rapidly there is considerable risk of attracting vermin. Where separate storage is provided, even worse conditions may be found, such as damp basements and underground cellars badly ventilated and overrun with rats. Sometimes the storage accommodation has even been in proximity to sanitary conveniences. It is suggested by at least one officer that in all cases flour should be stored on platforms raised sufficiently above the floor to permit of the whole floor surface being easily cleaned, while at the same time the sack-bottoms are kept free from damp and other deteriorations.

The cleanliness of the floor, shelves, cupboards and utensils in bakehouses is reported as a general rule not up to a satisfactory standard. In some cases floors are found with flour tramped into their surfaces and left to decompose gradually. The cleaning of shelves and cupboards is often omitted altogether, or the woodwork is merely wiped in a perfunctory manner. To facilitate cleaning, troughs and similar fittings should be mounted on wheels so as to be moved about readily.

Domestic animals, particularly cats, are to be found in some bakehouses. From the point of view of keeping down vermin they may have their uses, but against that there is the more serious objection that they may foul the bakehouse floors or even the food material itself. It seems desirable that they should be entirely excluded from bakehouse premises.

Better provision is required for the disposal of refuse, which too often is left lying for days in heaps on the floor. Covered receptacles for this purpose should be provided.

Cloakrooms and facilities for personal ablution are at present inadequate in all but the most up-to-date bakehouses. A separate room should be provided where outside wearing apparel can be left, and during work in the bakehouse each worker should wear

a clean washable overall.

Wash-hand basins and a plentiful supply of hot water, soap and towels should be provided to afford all workers an opportunity of washing before commencing work. Many come straight from common lodging-houses or from homes where little attention is paid to personal cleanliness, and without having made any attempt at washing themselves these persons start handling food in the bakehouse.

Restrictions should also be imposed on the employment of any person suffering from skin disease. One case is cited where a worker suffering from scabies was found employed in the manufacture of oatcakes. In another a baker suffering from weeping eczema was engaged daily, with his arms up to the elbows in dough. Several reports urge the periodic medical inspection of all food workers. At present young persons entering employment in a bakehouse undergo medical examination, and while this is satisfactory in that it ensures that only healthy persons enter the industry, there is no provision for detecting diseases subsequently arising during adult employment.

There are no restrictions on smoking and spitting in bakehouses, beyond what may be imposed by individual employers. Both practices are to be deprecated during work in a bakehouse, and, it is suggested, might be specifically dealt with under any amending legislation.

Reference is made in several reports to the promiscuous handling of manufactured bread and cakes, and the casual manner in which they are sometimes conveyed from the bakehouse to the shops. In some cases a certain amount of handling is probably unavoidable, but it might at least be compulsory that all persons so engaged should have clean hands and clean clothing.

(b) Butchers' Shops.-Criticisms are here directed not so much against the front shops of butchers, which in general show a reasonable standard of cleanliness, as against the back premises where food is manufactured. The fact that these back premises are not exposed to the public view to the same extent as the shop itself no doubt largely accounts for the different standards of cleanliness, though considering the great amount of foode.g. sausages, mince, brawn, &c.—which is prepared in these back premises, there is every reason for giving equal attention to their cleanliness. Often, however, these premises bear no evidence whatever of regular and thorough cleansing. Grease and dirt are allowed to accumulate unchecked, and form a breeding-ground for vermin. The lighting and ventilation of these places is frequently bad, and one report refers to the manufacture of sausage-meat in cellars, under most unhygienic surroundings. Even the mincing-machines, knives, &c. may not be periodically cleansed with boiling water. Refuse and waste material have been found left in a heap in a corner instead of being collected in covered bins and periodically removed.

As was noted in the case of bakehouses, the personal cleanliness of assistants often leaves much to be desired, and this is a

matter of special importance in butchers' premises, where the foodstuffs handled, by reason of their greasy nature, are very liable to retain any dirt they may take up during the process of handling.

(c) Fish and Chip Shops.-The demand for the "fish and chip supper has grown enormously within recent years, especially among the poorer classes. The trade in this commodity has to a great extent fallen into the hands of foreigners, many of whom have primitive ideas as to the value of cleanliness, and upon whom advice and exhortation may be largely wasted. The premises too are as a rule situated in the poorer quarters, and are often dirty and poorly lighted and ventilated. The cleansing and preparation of the fish and potatoes have been at times conducted under deplorable conditions,-e.g. in back rooms or even in cellars, with no supply of running water and with very primitive utensils. Storage is also unsatisfactory. One case is mentioned where a box of fish was allowed to lie in a hen-scraped backyard without any protection whatever. In the case of fish and chips sold from carts it has been found that these were prepared during the daytime within sleeping-apartments, doubtless not of the cleanest, and brought out to the carts in the evening.

More attention, it is suggested in one report, should be paid to the frequent internal cleansing of the vats in which the suppers are cooked, and to the complete renewal of the oils and fats.

(d) Ice-cream Shops.-This trade also is largely in the hands of foreigners, who occasionally combine it with that of fish and chip manufacturer. Ice-cream as a commodity containing milk or cream in its composition is particularly susceptible to contamination by dirty surroundings, and yet the only specific item of legislation which is capable of full enforcement is that it must not be stored or manufactured in any apartment where there exists a drain opening. There is indeed a general requirement that the ice-cream manufacturer must not do anything likely to expose the commodity to "infection or contamination," but in practice, provided the one specific requirement is met, it is difficult to exercise proper control over the conditions of manufacture and storage. The small dealer who produces ice-cream in his own house, and the itinerant maker and vendor of ice-cream, are instances in whose cases all kinds of unsatisfactory conditions may exist without much chance of effective interference by the local authority.

It may be added that where ice-cream is made entirely from milk or cream (with sugar added), the person and the premises are probably liable to registration under the Milk and Dairies Act, though it is not in the case of high-class ice-cream that registration is most called for. In many cases, however, as icecream is made from starchy material with milk and other ingredients added, it could scarcely be held to be a milk product, and accordingly the only powers of a local authority in these cases are those contained in the Burgh Police Act, 1903.

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