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THE WATER STANDARD. The attitude of the internal revenue department in regard to the enforce ment of the law defining and restrict ing the manufacture and sale of adul terated butter seems to be more or less doubtful so far as it affects the permissible water content of butter made directly from milk or cream. The department has repeatedly been called upon to define its position and intentions in this particular but in all the statements so far issued there has been a lack of definite expression. In the letter to New York Produce Review published in our issue of July 16, Robert Williams, Jr., acting commissioner recognized definitely the necessity of establishing a stand ard of maximum water content and stated that the department had no in tention of fixing for butter in general any different or higher standard than had been definitely fixed for renovated butter. From this the conclusion was naturally drawn that it was intended to consider as adulterated all kinds of butter containing sixteen per cent or more of water and to enforce the law on that basis. Yet it is to be noted that the department did not state this in positive terms, and it is quite possible that the broad construc tion placed upon Mr. Williams' letter to the Review, while quite natural, was not intended. This view is strengthened somewhat by the fact that as a conclusion from the first part of his letter, referring to the ne cessity for a standard and stating that it was not intended to establish any standard for other butters different from that fixed for renovated, Mr. Wil liams cautioned makers of mixed, re worked and rechurned butters to see that their product came within the six teen per cent, limit, but made no di rect allusion to creamery or dairy but ter. In fact a critical consideration of all statements made by the internal revenue department in answer to in quiries indicates what is probably the fact, that the department is consider ably at sea as to the extent to which the law defining and regulating adul terated butter can be enforced, and as to the method of such enforcement. It is plain that the provisions of the law are to be applied to all process butter and to all re-worked butters, in all of which a water content of six teen per cent, or more will throw the goods into the class of adulterated. But although it has been definitely stated that no different or higher stan dard would be fixed for other butters we have seen no positive statement that this standard would be applied to butters made directly from milk or cream. It looks as if the proposi tion of applying this standard to all creamery and farm dairy butter had brought up considerations of method and capacity of such nature as to in duce a carefully guarded conserva tism in all proclamation! of inten tion; and while the utterance! of the Depaitment have given the impres sion that all butters should lie kept below sixteen per cent of water con tent to be within the law it seems probable that no conclusion has yet been reached as to the method of en forcing the law except as to re-worked, mixed and renovated butters. It appears to us that in enforcing a law prohibiting "abnormal" water content in butter, a law which makes no distinction as to kind, it would be arbitrary and illogical for tli<• authori ties to single out any particular kind PROF. JUDSON P. WILSON, of butter and fixing a standard or in applying the law. The extreme diffi culty of enforcing a rule prescribing a maximum water content for all but ter is evident, but if it were plainly stated by the Department that its in tention was to apply the law on that basis to the best of its ability, makers would doubtless find a means of keep ing their product within the legal re quirements. in this connection we wish to call attention to the difficulty of determin ing with any accuracy the amount of water in a sample of butter by any ap paratus available for popular use. The test by evaporation requires expert knowledge of temperatures and their effects and takes time; simple melt ing in a graduated test tube is far from accurate. It is much easier by the latter means to determine the fat percentage and we think it would be much better if the Department rul ings had prescribed a minimum fat requirement, rather than a maximum water content. WATER CONTENT OF BUTTER. (Elgin Dairy Report.) The Treasury Department has fixed the standard of water in butter at less than 16 per cent. The Uren-Barry Company has corresponded with the Treasury Department regarding the provisions of the oleo law regarding the water content of butter, and re ceived from the Treasury Department the following communication. We give it entire for the information oi our readers. To the ordinary reader it would seem as if this ruling applied to all kinds of butter whether made on the farm, factory, reworked or ladled, and if this is the case, it will be de cidedly to the advantage of butter consumers as the tendency has been in many cases to overload not only dairy but creamery butter with water. TREASURY DEPARTMENT Office of Commissioner of Internal Revenue. Washington, July 7, 1902. Urea-Harry Co., Sirs: I have received your letter of the 2Gth ultimo, in which you make THE RANCH. HOME OF WILSON'S MODERN BUSINESS COLLEGE, SEATTLE. inquiry as to whether the limit of 16 per cent, for moisture in renovated butter will bo held to apply to butter manufactured and manipulated by oth er processes, and not coming under the designation of renovated butter. While the law does not fix a maxi mum standard for moisture in butter, it was necessary for a proper execu tion of the law that standard should be fixed by the regulations of this De partment, to be acquiesced in by the Department of Agriculture, and after the limit was fixed as it appears in the regulations under the head of rtno vated butter, that is below 16 per cent. While the regulations refer to exces sive moisture in renovated butter only, it is not the intention of this office to fix another and higher maximum for butter that does not come under the designation of renovated butler. Persons engaged in mixing, rework lllg, rechurning, etc.. different lots or panels of butter, must see to it that their finished product does not contain 16 per cent, or more of water, milk or cream, in order to avoid liability to ■pedal tax as manufacturers of adul terated butter, and a tax on their pro duct of ten cents per pound. In reply to your question regarding the requirements of the regulations that renovated butter facories roust be entirely separate from those used for the manufacture of adulterated butter or oleomargarine, or for the handling or manipulation of butter not taxable under the act of May 9, 1902, you are advised tnat it is the intention of these regulations to require that such business shall be carried on separate and apart from the other businesses mentioned. Two or more of said businesses can be carried on in the same building provided they are separated by solid walls or partitions from each other, having no openings or passage ways between. It is the intention of this office to rigidly enforce this require ment. Respectfully, ROBT. WILLIAMS, Jr., Acting Commissioner. BUILD PERMANENT SILOS, When a silo is to be constructed it is generally better to build one that will last for a long time if the farm is owned by the man that wants to build the silo. Of course, if the farm be in the possession of some one else the problem is a different one. In that case a man is justified in building a cheap silo even though that silo will last but a few years. The advantage of having a permanent silo is that it can be cemented and the wood be thus kept from absorbing moisture from the silage. This preserves it from rot due to moisture. The silo will then be in condition to do good work year after year without the need of patching or of looking after it. This is a great point in the running of any such thing. Where a silo has to be looked after several times a year, its hoops tightened or loosened, and other changes made, it is almost certain in a few years to fall into dis use from neglect on the part of the farmer. Not because the farmer wants to neglect the work, but be cause there are generally so many things of the kind to be looked after that he does not find time to get around to all of them. Things should therefore be so constructed that they will do good service year after year with little or no attention on the part of the men that are to use them.