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The staff at present consists of a whole-time director and a part-time secretary. The small office, originally intended for a storeroom and having one small window, is shared with the administrative assistant of the board of licensure. The budget is as follows:

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By A. W. FUCHS, Senior Sanitary Engineer; F. J. Moss, Sanitary Engineer; and L. H. MALE, Assistant Public Health Engineer, U. S. Public Health Service

Recommendations-It is recommended—

1. That the grading type of milk ordinance recommended by the Public Health Service be adopted as regulations and adequately enforced. This may require -congressional legislation to authorize grading in place of scoring of dairies and dairy farms. For a discussion of the advantages of grading over scoring, see section on milk control.

2. That the grading type of frozen desserts ordinance and of resturant ordinance to be released in the near future by the Public Health Service, be adopted as regulations and adequately enforced.

3. That the services of a public health engineer be made available to the bureau of food inspection for handling technical problems in connection with equipment of milk and ice cream plants, cross-connections between safe and unsafe water supplies in food factories and milk plants, the pollution of water by backsiphonage from toilets and sinks in establishments where food is handled, and similar problems.

4. That the several minor recommendations as to details, incorporated in the text of this report, be given careful consideration.

5. That inspection and laboratory results for each dairy or food-handling establishment be combined on a single record form for easier reference.

MILK AND FOOD CONTROL

Organization and expenditures.-Milk sanitation and food inspection are included in the bureau of food inspection, consisting of two divisions. The dairy farm, dairy, and livestock division is charged with the inspection of dairy cattle, dairy farms, milk pasteurization plants, meat slaughtered for local consumption, and the examination of dogs reported to have bitten persons. The food division inspects ice cream plants, eating and drinking establishments, bakeries, food factories, groceries, and similar places where food is manufactured, handled, stored, or served.

The number, professional training, and salaries of the bureau personnel, together with the appropriation for the fiscal year ending June 30, 1938, are presented in the accompanying tabulation. The milk inspection personnel and appropriation have been segregated from the other activities as far as possible.

Summary of personnel and appropriation, fiscal year 1938

Bureau of food inspection:

Milk inspection service:

1 Chief of bureau, veterinarian, at $4,600 (half time).

1 Assistant chief, at $2,600 (half time).

$2,300 1,300

8 Dairy farm inspectors, veterinarians, 5 at $2,700, 3 at $2,600___ 21, 300 1 City milk inspector, at $2,300 (city pasteurization plants) ––

1 Sample collector, at $1,920‒‒‒

1 Part-time sample purchaser, at $200 (half time)–

1 Clerk, at $1,560 (half time) –

Total salaries_.

2,300

1, 920

100

780

30,000

Supplies, transportation, maintenance_.

4, 088

Total, milk and biting dogs inspection_‒‒‒

Less dog inspection: half time of 2 farm inspectors

Total, milk inspection__

Food inspection service:

34, 088

2,700

31, 388

1 Chief of bureau, veterinarian, at $4,600 (half time)
1 Assistant chief, at $2,600 (half time)‒‒‒

2, 300

1, 300

1 Market inspector, veterinarian, at $2,600 (slaughter houses,
etc.)

2, 600

11 Food inspectors: 1 at $2,000, 9 at $1,920, 1 at $1,860 (1 on
ice cream, 3 on restaurants).

21, 140

4 Food inspectors, at $1,800 (bacteriologists on restaurants) -- 7, 200 1 Senior clerk, at $1,800___

1,800

1 Clerk, at $1,560 (half time).

780

1 Part-time sample purchaser, at $200 (half time) –

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In addition to those listed, a considerable portion of expenditures for the bacteriological and chemical laboratories of the health department should be apportioned to milk and food control. The following segregation of laboratory personnel and expenditures is based on available estimates:

Laboratory personnel and expenditures for milk and food control Bacteriological laboratory:

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1 Laboratory director, at $4,600 (ice cream 7, food 3⁄4)

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The estimated total cost of milk and food control for the fiscal year 1938 is, therefore, $79,253, exclusive of inspection of biting dogs. Of this, $34,653, or 5.7 percent of the total congressional appropriation for the health department, is for milk control, as compared with 5.36 percent for large cities in 1923, the latest comparable figures available. The cost of milk control may also be expressed as 5.5 cents per capita per year, or two-tenths of a cent per gallon of milk, or $26 per dairy farm or dairy per year. These unit costs compare with 5.6 cents, 0.16 cent, and $7.30, respectively, for 10 cities of over 500,000 population in 1936. The relatively high cost per dairy or dairy farm is related in part to the larger average size of producing farms on the District of Columbia milk shed (36 gallons per day) than for the 10 large cities (12 gallons per day), and in part to the high frequency of physical examination of cattle. The balance of $44,600, or 7.4 percent of the total health department appropriation, is for food control, as compared with 7.3 percent for large cities in 1923. This amounts to 7.1 cents per capita.

The present personnel and budget for milk and food control are considered adequate for the needs of the present and the near future.. Any moderate increase in the bureau's work accompanying a growth of population could be handled by the present personnel by reducing the frequency of inspection of dairy cows. The practice of examining every dairy cow whenever a farm inspection is made is unusual, and accounts for the relatively small number of dairy farm inspections: (average 4 per day) per inspector. In view of the additions to the bureau personnel since the Preble survey of 1927, the overcrowded condition of office quarters noted then has been aggravated rather than diminished.

The personnel of the bureau includes veterinarians, bacteriologists, and lay inspectors, but there is no public health engineer for handling such technical problems as arise in connection with equipment of milk and ice cream plants, cross-connections between private and public water supplies in food factories and milk and ice cream plants, the pollution of water supplies by backsiphonage from toilets and sinks, and similar problems. It is believed that the services of an engineer should be available to the bureau for such duty.

MILK CONTROL

Production and consumption.-The fluid milk and cream supply of the District of Columbia comes from 11 raw-milk producer-distributors (including 1 certified and 1 goat milk dairy), 13 pasteurization plants (including 4 farm plants), and 1,293 farms producing milk for pasteurization on a milk shed extending into 4 States (Maryland, Virginia, West Virginia, and Pennsylvania). The milk from 300 of these farms is routed through one country collecting station.

The total daily sales of fluid market milk, cream, and buttermilk within the District of Columbia at the time of this survey averaged 46,977 gallons, or 0.60 pint per capita per day, nearly all of which (99.2 percent) was pasteurized. These figures compare with means of 0.75 pint and 96.8 percent, respectively, for cities of over 500,000 population in 1936. The relatively low per capita consumption in the District of Columbia is probably associated with the higher percentage of Negroes than is found in most cities of this size. The average age of the milk sold is 48 hours. As the raw milk sales constitute only 0.8 percent of the total (including 0.2 percent certified), .consideration might well be given to the compulsory pasteurization. of all milk.

Legal provisions.-Authority for the sanitary control of milk is contained in the act of Congress of February 27, 1925, and in the regulations promulgated by the District Commissioners in November 1925, July 1935, and March 1937, under the authority conferred by the act. Enforcement is based on the issuance of annual permits and their suspension for cause. The act specifies the following minimum scores on the rating cards currently used by the health department: For raw milk, farm 80, cattle 95, and dairy 90; for pasteurized milk, farm 70, cattle 90, and plant 85. The score cards recently adopted, one for dairy farms and cattle and the other for pasteurization plants, attempt to compensate for the lack of detailed requirements of the act and the regulations. The former contains most of the dairy farm requirements of the United States Public Health Service Milk Ordinance, and the latter was designed after the United States Public Health Service Plant Inspection Form. The score awarded a pasteurized milk dairy is the average of the farm score and the cattle score of the contributing producers, the plant score, the total-solids score, and the bacterial score of the pasteurized milk, with the last given twice the weight of each of the others. The weight assigned to laboratory results (50 percent of the total) is believed to be excessive. The score awarded a raw milk dairy is an average of the same scores, with the plant score omitted. Beginning this year, all items referring to construction and equipment are being made mandatory on both score cards. Tuberculin testing is mandatory for all herds, and abortion testing for all herds producing milk to be consumed raw.

The milk scores are mimeographed monthly and 500 copies are sent to interested persons. Considerable improvement has resulted among plants and dairies from the competitive effect of scoring, and among producing farms from the bonus paid by the plants for high scores. Nevertheless, it is believed that a grading type of ordinance, like thai of the United States Public Health Service, is preferable for the following reasons:

(1) The present milk scores are distributed only to about 0.5 percent of the families, whereas a grade label on each bottle cap would serve every milk consumer as a guide to the sanitary quality of the milk purchased.

(2) Even if milk scores were known to all consumers, they would not serve as useful a purpose as grades on bottle caps. The public is apt to exaggerate the significance of small differences in the milk scores of two dairies, and would be tempted to change each month from the last high-score dairy to the new high-score dairy. The same tendency has been noted where bacterial counts are published. In effect, this is equivalent to official recognition of a large number of grades, with each score representing a different grade. On the other hand, a change from grade A to a lower grade would really be significant and would immediately be obvious to milk consumers from the grade label.

(3) A dairy or plant may obtain a high score even if an important item of sanitation is violated. This objection may be overcome either (a) by requiring a certain minimum score, together with compliance with all important items of sanitation, or (b) by awarding a lower grade for repeated violation of any item of sanitation, as in the United States Public Health Service Milk Ordinance.

(4) The health department could conscientiously undertake an educational campaign to promote the consumption of the highest grade of milk, but cannot soundly urge the purchase of only the highest-score milk.

In effect, the scoring type of ordinance establishes minimum requirements for all milk, thus making degrading impossible for violation of any of these minimum requirements and forcing the health officer to resort to permit revocations and court procedure. The latter methods constitute in many cases too severe a penalty, hence most health officers hesitate to employ them except for very serious infractions. Thus, the District prosecutes only for watering, and it revoked only eight producing farm permits during 1937.

Inspections. Retail raw milk producers were reported to be inspected monthly by the health department during 1937. The 9 city milk pasteurization plants were inspected 924 times by the city plant inspector, or an average of 103 times each, while the 4 farm pasteurization plants were inspected monthly by the farm inspectors, with occasional inspection by the city plant inspector. The latter should be given more frequent attention by the plant inspector who should be furnished with adequate transportation facilities for this purpose. The country collecting station was visited approximately semiweekly for temperature check on incoming milk. A total of 6,676 inspections of producing farms was made by the veterinary farm inspectors, or an average of 5.2 per farm. The 37,120 cattle on dairy farms were

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