U. S. DEPARTMENT OF AGRICUJLT COOPERATION. THE POLICIES OF COOPERATION BETWEEN FED- ERAL AND STATE FOOD AND DRUG OFFICIALS RECOMMENDED AND ADOPTED BY THE AMER- ICAN ASSOCIATION OF DAIRY, FOOD, AND DRUG OFFICIALS. State and Federal Food and Drug Officials: Your attention is respectfully called to the specific policies of cooperation between State and Federal food and drug officials which have been adopted from year to year by the American Association of Dairy, Food, and Drug Officials upon the recommendation of its members and of its committee on cooperation. The last report of this committee, adopted at Portland, Me., in July, 1914, contained an outline of the duties of the United States Department of Agriculture on the one hand and of the State dairy, food, and drug departments on the other hand. The carrying out of these established policies of cooperation requiring continuous work has been the first consideration and effort of the Office of State Cooperative Food and Drug Control of the Department of Agriculture. DIVISION A. THE FUNCTION OF THE UNITED STATES DEPARTMENT OF AGRICULTURE IN REGARD TO COOPERATION. The recommendations of the association as they a: this department arc as follows: 1. That the guaranty Legend be abolished. 2. That an office be established in the Bureau of Chem- istry as a sort of clearing house (or putting into effect the policies of cooperation adopted by the association. 87713—15 3. That the Secretary of Agriculture invite and encour- age State officials to ask for information and advice which they need in the enforcement of their laws. 4. That the Secretary of Agriculture appoint one or more persons connected with the Department of Agri- culture to meet and act with the committee on cooperation of the American Association of Dairy, Food, and Drug Officials. 5. That there be created a joint committee on defini- tions and standards, consisting of three members of the United States Department of Agriculture, three members of the American Association of Dairy, Food, and Drug Officials, and three members of the Association of Official Agricultural Chemists, to adopt suitable definitions and standards of food and drug products. 6. That the Department of Agriculture supply State officials with new methods of analyses which have been approved by the Secretary of Agriculture. 7. That the Department of Agriculture furnish State officials with information of violations of the Federal law originating in their respective States. 8. That United States food and drug inspectors report to the proper State officials the violations of State laws coming under their observation. 9. That the Department of Agriculture and the food and drug officials give to the proper State officials full informa- tion concerning perishable food or drug products shipped from their States in interstate commerce with the request that such State officials make appropriate investigations of the source of such products and the sanitary conditions under which they are manufactured or produced. 10. That United States inspectors at the request of State officials be instructed to collect samples of intrastate ship- ments of food and drug products which appear to be illegal and to send them to the State officials concerned. COMMENTS ON THESE RECOMMENDATIONS. The Department of Agriculture, as you are already aware, has complied with the first five recommendations. 6. The Bureau of Chemistry is not only supplying State officials with new methods of analysis, but it is supplying them with the investigational and scientific data in the possession of the bureau as fast as it can be collated. Letters received from many State officials concerning this work indicate that they consider it to be of very great value to them and that it is most highly appreciated by them. An effort is being made to secure the assistance of the State officials in making additions to this sort of information from similar data in their possession. If the work is carried out as it should be, the result will be a most important manual for food and drug officials. 7. The bureau is now furnishing State officials with information of violations of the law as soon as it is possible to do so after such violations are passed upon by the proper authorities. The circulars giving notice of seizures, which go to our own laboratories, are also going to the State officials. These circulars are prepared as soon as the cases are passed upon by the Department. Information of this nature may be given to State officials through the chiefs of the three districts of the bureau while working up evidence concerning apparent violations of the law in their States. This, however, is a matter of detail which will have to be worked out through the chiefs of the three districts. 8. Our inspectors have been notified to inform State officials of what appear to them to be violations of State laws. A form letter for use in making such reports has been prepared for the use of our inspectors. Our inspec- tors are carrying out the spirit of this recommendation. Two such letters received by me when I was in office in Texas conveyed to me valuable information concerning violations of the State law, which were thereupon stopped. Such information is also furnished to State ollicials by our inspectors in person. 9 and 10. It is not known to what extent requests for such assistance have been made to officials of tin 1 Bureau of Chemistry concerning these two phases of cooperation. It is safe to assume, however, from the general attitude of such officials toward this cooperative movement that these recommendations will be complied with as occasions arise. DIVISION B. THE FUNCTION OF THE STATE FOOD AND DRUG DEPART- MENTS IN REGARD TO COOPERATION. The recommendations of the American Association of Dairy, Food, and Drug Officials with respect to what State officials should do in this connection are as follows: 1. That State officials give the Bureau of Chemistry in- formation concerning violations of the Food and Drugs Act. 2. That State officials give the Bureau of Chemistry all new information which they secure pertaining to official work and investigations. 3. That State officials make factory inspections and other necessary investigations in their States for the Bureau of Chemistry when called upon for such service. 4. That State officials place their inspection forces at the service of the Bureau of Chemistry for such assistance as may be desirable. 5. That State officials prepare circulars of confidential information concerning illegal drug preparations and send them to other State officials and to the Federal officials. COMMENTS ON THESE RECOMMENDATIONS. 1. This recommendation corresponds to recommenda- tion 8 concerning the duties of the Department of Agri- culture. The faithfulness with which these recommenda- tions are carried out will in a large measure reflect the value of the effort to establish a working system of cooper- ation. Each set of officials is continuously learning of violations of laws with which other sets of officials are con- cerned. This is right where cooperation may be effective. Such information will enable the city, State, and Federal organizations to enforce their own respective laws with the least expense of time and money. Cooperation does not mean that one organization shall enforce laws for another organization. This may be done, however, with great advantage and propriety when quick action is imperative, as when an illegal product is shipped interstate and found by a State organization in original packages in the hands of the original consignee. The State organization may then perform the functions of the Federal organization and secure the evidence necessary to start appropriate proceedings against the goods and even against the shipper outside his State, independently of the Federal organi- zation. If these two recommendations are earnestly carried out, the collection of samples will be reduced largely to prod- ucts known to be illegal rather than to products supposed to be illegal. This is where city and State officials can assist the Federal officials as well as each other. This will mean that when one of these organizations finds an illegal product it will say to the manufacturer or producer of that product, "You can not sell your product here or anywhere else until it complies with the laws." 2. This recommendation that State officials give the Bureau of Chemistry all new information which they secure pertaining to official work and investigations corresponds to recommendation 6 concerning the work of the Depart- ment of Agriculture. Such information should come to this office and be distributed among the city, State, and Federal officials and offers a big opportunity to such offi- cials for securing valuable information. A considerable amount of valuable information of this sort is now passing through this office to food and drug officials. 3 and 4. The State officials whom I have visited have expressed a willingness to comply with these two recom- mendations whenever called upon by this department. They have placed their inspection forces at the service of this department for such assistance as may be desired. 5. This recommendation that confidential information concerning illegal drug preparations be sent to other State officials and to the Federal officials is in substance the same as recommendation 1. Your assistance is earnestly desired in the effort to establish a continuous compliance with the recommenda- tions that officials supply each other through this office with all new information which they secure pertaining to official work and investigations. Respectfully, J. S. Abbott, Chemist in Charge, State Cooperative Food and Drug Control. WASHINGTON: GOVERNMENT PHINTINO OFFICE ! 1918 UNIVERSITY OF FLORIDA 3 1262 09227 1468