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PERSONNEL OF THE STAFF.

In no single particular does the success or failure of the work depend in such great degree as on the personnel of the staff. Getting satisfactory men is an extremely difficult problem. Two almost insurmountable difficulties stand in the way. The first is the matter of salary. Good milk inspectors are notoriously underpaid in this

. country, and yet I venture to say without fear of contradiction that many men who are milk inspectors are getting more money than they are worth. City councils, and particularly their finance committees in control of the municipal purse strings, who have to do with a comparatively large body of employees, and fix salaries along uniform statutory lines, have not, up to the present time, recognized the qualifications necessary for such positions. The desired ability is possessed only by men who are worth more money than the salary that goes with the place, and therefore ideal men must be especially interested in the work or remain with it for other reasons than the actual money return received for the services rendered.

The other obstacle, after the appointment of men with proper qualifications, is securing for them the opportunity to work unhampered by political considerations. It requires character and singleness of purpose to crowd an obstinate dairyman whose brother or other close family relative is in a position of influence and accustomed to getting special privilege. One such man, if successful in his efforts, can greatly discourage an otherwise good inspector.

Appointments are usually made by competitive civil service examinations, a system which has many advantages, but one which renders it discouragingly difficult to remove incompetents. In examining men the civil service commission must make a generous allowance for experience and personality with a corresponding reduction in credit for the written examination. Many well-educated men. who can turn in an examination paper which grades high, are totally Jacking in the essential qualifications of successful inspectors. Such inspectors must have a strong personality, good public contact ability, and an agricultural training. They should have a good knowledge of dairy husbandry, the construction of dairy buildings and drainage, with a practical knowledge of sanitation and the factors essential to keeping the bacterial content of milk at a minimum. It is not necessary that they should be veterinarians, but one or more men with veterinary training should be on the staff

, if not in charge of it, on account of the fact that the health of animals must be more or less constantly passed upon.

LEGISLATION.

Proper legislation is necessary as a foundation on which to build the work. California has been particularly fortunate in this respect through the passage in 1915 of a State pure-milk law carrying a comprehensive grading system. It is an act to prevent the sale of impure and unwholesome milk, butter, ice cream, and other milk products: to declare ice cream a milk product; to grade milk; to provide rules and regulations therefor; and to empower cities, groups of cities, counties, and groups of counties, or cities and .counties to establish inspection service, to provide for the enforcement of the act, to prescribe penalties for violation of the provisions thereof, and to make an appropriation therefor. Any city in the State desiring to avail itself of the provisions of this enabling law, makes application, for approval of its inspecting department, to the State department of agriculture, which administers the provisions of the law so far as the State is concerned. Those cities, such as Los Angeles, which had ample city ordinances and had been carrying on milk inspection for years with an adequate corps of full-time inspectors, were in an ideal position to avail themselves of its grading provisions and to proceed immediately to put them in force. The law provides for the following grades:

Certified milk under the rules and regulations of the certified milk commissions.

Guaranteed milk, raw or Pasteurized, the requirements for which are left to the local inspecting department.

Grade A raw milk, produced from cows that pass a tuberculin test applied free of charge by the veterinarians of the State bureau of animal industry. Such dairies must score 70 points on the detailed score card, and the milk must contain less than 100.000 bacteria per c. c. when delivered.

Grade A Pasteurized milk, from dairies scoring 60 points and containing less than 200,000 bacteria per c. c. before Pasteurization, and 15,000 afterwards when delivered.

Grade B Pasteurized milk, which shall contain less than 1,000,000 bacteria per c. c. before Pasteurization and 50.000 afterwards when delivered.

City ordinances covering the milk regulations must be carefully prepared in order to be proof against legal technicalities. The ordinances should provide for the permit system by which each distributor must apply for and receive a permit from the health department. To hold such permit he must keep the health office informed as to his source of supply, etc.

Matters which can not well be covered in the ordinances may be prepared in the form of rules of the health commissioner. These are then approved by the council, and this approval gives them the power of ordinances. In the city of New York, the board of health has the power to adopt rules and regulations governing the public health side of the milk business. A regulation on such matters adopted by the board and filed with the city clerk becomes a law with a severe penalty clause covering violations. This is an ideal situation for very large cities with experienced health officials. It can not be expected that delegation of such power would meet with the approval of the legislative bodies of many cities. Where health boards are constantly changing, the possibility that new men with little experience may gain control might result in some disadvantage with such a system.

COURT WORK.

Resort to court work should be had only after due thought and consideration. Measuring the success of the work by the number of complaints sworn out and convictions obtained is an exceedingly poor index. As far as possible, a general policy covering this work should be maintained to prevent special privilege from time to time. gaining the upper hand. For example, all cases of added water or skimming should go to court. This is attempted by small operators only and recourse to the court seems to be the most effective way to stop the practice.

The maintaining of butterfat standards in restaurants is difficult on account of the constantly changing personnel of owners and employees in this business. Low butterfat samples from such places are usually evidence of carelessness in not stirring the milk so that part of the supply is served with too much fat and part with too little. A good policy in such cases is to allow samples not more than five-tenths per cent under the standard to go with a warning, and to take all cases below this to court. For example, if the butterfat standard is 3.5 per cent fat and samples are collected between 3 and 3.5 per cent, the restaurant owner is notified that the milk is not being properly handled. When samples are taken which test below 3 per cent fat, the owner is required to appear in court. This has proved effective in having milk properly handled from the time it is delivered to the restaurant until it is served on the table. Restaurant samples must be taken during meal hours.

Occasionally sitigation is necessary to settle disputed problems of great importance to the industry. Such cases must be properly prepared so they may be tried on their merits and not thrown out of court on technicalities.

In general, court cases should be kept at a minimum, and the department should have the reputation of resorting to prosecution only when necessary, with carefully prepared cases which result in a high percentage of convictions.

METHODS.

In carrying on the work the staff must be divided into dairy inspectors, city milk plant inspectors, sample collectors covering wholesale samples to be Pasteurized, wagons, stores, and restaurants. A corps of 10 or 11 full-time inspectors, with a chief, and a wellequipped laboratory, is sufficient to handle properly the milk supply of a city of 600,000 people. With transportation furnished the men, the cost of the work will run from $25,000 to $30,000 per annum. This money should preferably come out of the general tax levy and no fees be charged to the dairy industry.

The dairy inspectors should have official headquarters in the dairy districts. The practice of some cities requiring inspectors to maintain residence in the corporate limits of the municipality seriously reduces efficiency. They may be brought into the office for meetings of the staff weekly, monthly, or quarterly, depending on the distance they have to travel. The dairies are scored on the detailed score card. Its value is not as great as was at one time considered, but it still remains the best method at hand of keeping on file information regarding the relative standing of all dairies and the work being done by the men. Its value is greatly enhanced by maintaining minimum standards below which the product is degraded or excluded from the city. Where minimum standards are enforced, printed

. rules for using the score card should be in the hands of each in

spector. In case of argument these rules are shown to the dairyman and this prevents him from conceiving the idea that his low score is due to any personal feeling between him and the inspector. These rules are also of great assistance in having a corps of inspectors score uniformly.

The dairy inspectors are constantly informed by telephone or mail of the bacterial standing of the milk from dairies in their respective territories. Degrading is done when 80 per cent of the samples fail to meet the standard for the grade. No court work is necessary to maintain grades, because the reduced price a dairyman receives when degraded from A to B or B to butterfat automatically fines him from one to several hundred dollars a month in case the dairy is of any size. Reinstatement to grade is made only after five samples are taken, four of which are within the standard, and a period of two weeks is usually the shortest time in which this work can be carried out.

When requested, full assistance should be given on the ranch in ascertaining the trouble and how to overcome it. Considerable time on the part of the staff is sometimes spent in this work, but it is time well spent, because it is given where it is needed and does the most good. Information on incoming high-count milk is obtained from the health office laboratory, or attention is called to it from the counts regularly made by the milk-plant laboratories, free access to the records of which should always be available.

At the time grading was started in 1916, very valuable cooperation of some of the milk plants was secured in the payment of a sliding scale of premiums for milk, depending on quality, as ascertained by bacterial count and the sediment test. The premiums were arranged approximately as follows:

25 cents a hundred pounds for milk under 10.000.
15 cents a hundred pounds for milk under 50,000.

10 cents a hundred pounds for milk under 100,000. All of the dairies were equipped with sterilizers, hooded milk pails, and water-cooling facilities. In southern California, the temperature of the water coming out of the ground is between 60° F. and 74° F. Natural ice is unknown, and to the majority of dairies the cost of artificial ice is prohibitive. For this reason, the temperature standard of milk coming into the city is 70° F. During warm weather delivery is made twice daily from the ranches. The sterilizer in most common use and which has been highly successful is described by C. L. Roadhouse in Circular 179 of the University of California Agricultural Experiment Station, “Factors of Importance in Producing Milk of Low Bacterial Count.” Sterilization is by a wide margin the most important factor in reducing bacterial count. The equipping of dairies with sterilizers is much easier of accomplishment than getting them regularly used.

The premiums paid, together with the thorough education that had been carried on among the dairymen from the time the law was passed in the spring of 1915 and its going into effect on October 1, 1916, resulted in remarkable improvement in the bacterial count. In a very few months 90 per cent of the supply of milk to the city of Los Angeles to be Pasteurized met the requirements for grade A, and all bottled milk in the city has been grade A since that time. An effort was made to put out bottled milk grade B for the grocery trade. There was great opposition to this by the trade, and this opposition, coupled with the enormous volume of grade A available and the competition of plants putting out only grade A, forced the grade B milk completely off the market. At present, only 7 of the 16 Pasteurizing plants handle two grades, and they distribute about 7,000 gallons of grade B in 3-gallon cans to the restaurant trade, a considerable part of which is of a quality to meet the requirements for grade A. The city consumes about 70,000 gallons of milk daily, of which 86 per cent is Pasteurized.

CONTINUOUS MILK-SCORING CONTEST PERIODS.

The organization of continuous milk-scoring contests is a very important aid to a health department properly organized to successfully carry out the work involved. The milk score card was originally developed by C. B. Lane, in 1906, and was for many years used in scoring milk at fairs. It is well-known that in these contests the samples presented had been produced under special conditions, and in no way represented the daily quality of the milk placed on the market by the various exhibitors. It was from this beginning, however, that the Dairy Division of the United States Bureau of Animal Industry developed the idea that the milk score card could be made of great service if it could be used to record the actual quality of the milk delivered in any particular community. From this there evolved a means of cooperation between the Dairy Division and municipal health departments, by which continuous milk-scoring contest periods were established, covering all the distributors of milk in the cities carrying on the work. J. E. Dorman, in charge of the western office of the Dairy Division, with headquarters at Salt Lake City, deserves credit for the installation of this work, and F. H. Bothell, formerly market milk specialist with the bureau, for the growth and development of the system in the coast cities. The details of these contests are fully described in United States Department of Agriculture Circular 53, entitled “ Milk and Cream Contests,” by Ernest Kelly and George B. Taylor.

To carry on the work successfully, the health department must be organized to collect at least two retail samples monthly from all distributors, and more from the larger ones. The samples are examined for bacterial count, butterfat, and solids not fat, and the results recorded in a card-index system. When the work is started all milk dealers should be notified. At the end of the first contest they should be placed in their proper standing, and a copy sent to all distributors, but otherwise no publicity should be given. This gives an opportunity for all interested to become thoroughly acquainted with the work. A new contest period starts immediately, and thereafter the results are given wide publicity in the newspapers. The daily papers do not always desire to accept such material, but their cooperation is so essential that all legitimate means must be used to have the copy accepted for publication. Information must be protected and copies go to all newspapers at the same time. Either the afternoon or morning papers will then get first publication, but this can be alternated.

When the contest period is to close, which may be at the end of three, four, or six months intervals, a representative of the Dairy

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