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The encroachments of trade practices on the enforcement of the Food Law will be shown in the last chapter.

I refer solely to the illegal and unethical practices. They are also likely to be dominant in the activities of the Bureau of Standards in the case of scientific associates. It is even possible that activities of the Food and Drugs Act, or the investigations of the Federal Trade Commission may be invoked to restrict the scientific investigations of the Bureau of Standards. One of the dangers which attend the exploitation of trade practices is illustrated by the attitude of the Bureau of Standards in regard to Castile soap. The methods employed by the manufacturers of so-called Castile soaps are thoroughly outlined in Circular No. 62 of the Bureau of Standards devoted to this subject. The trade practices are set out in detail. Brands of Castile soap are made which are entirely foreign to the original idea universally accepted of this article. In the data below it will be noticed that the principal chemist who has been consulted in this matter, and whose suggestions have appaxently been adopted, is the chemist of a firm making so-called Castile soaps of different kinds without any olive oil whatever entering into their composition.

The Food and Drugs Act was passed for the purpose of correcting trade practices. Now the efforts of the Bureau of Standards seem to be directed toward establishing them as ethical processes. This, of course, means great danger to the consuming public. A great government organization ought not to aid fraudulent trade practices and try to foist them upon the public, even by mentioning them approvingly.

" Castile Soap was originally made from low-grade olive oils. The name now represents a type of soap, the term 'castile' being applied to a soap intended for toilet or household use, sold usually in large, unwrapped, unperfumed bars, which are cut up when sold or when used. It is often drawn directly from the kettle without 'crutching,' but is sometimes crutched a little or even enough to make it float and is sometimes milled. It is also sold. in small bars both wrapped and unwrapped. The type is not one easily defined, so now when made from olive oil it is invariably sold as olive-oil castile. There are soaps made entirely from cocoanut, oil which are sold as cocoanut castiles or hardwater castiles. Many other castiles are made from a mixture of cocoanut oil and tallow." (Dept. of Commerce--Circular of the Bureau of Standards, No. 62--SOAP--p. 9, Jan. 24, 1923.

NOTE: Previous Edition of Standard Circular No. 62 (Second Edition June 17, 1919, p. 7) reads as follows:

'Castile soap, otherwise known as Marseilles or Venetian soap, is prepared from low-grade olive oil.

A letter from Director of the Bureau of Standards, dated September 22, 1924, explains the change in language note above:

"As stated in our letter of Sept ember 9, the statements made in paragraph (c) page 9, of the third edition of our circular No. 62 were intended to give information as to conditions as they are at the present time rather than as to what they should be.

"The Bureau has not issued a specification or set up a standard for Castile Soap, nor has the bureau intentionally, in a passive way or otherwise, injured any existing standard or trade practice regarding this commodity. Our sole aim in circular 62 was to state the facts as we found them." * * * (Signed F. C. Brown, Acting Director; George K. Burgess, Director.)

A further explanation by Dr. Burgess, Director, in letter to T. R. Lockwood, March 27, 1926, is as follows:

" The statements were approved by the Soap Committee of the Soap Section of the American Specialty Manufacturers Association, as indicated by the following quotation from Circular No. 62 (page 4):

'The Bureau has received much valuable assistance in the preparation of this circular from the Soap Committee .of the Soap Section of the American Specialty Manufacturers Association, and especially Messrs. A. Campbell and C. P. Long, chairman and secretary of the soap and soap products committee of the American Chemical Society, for which it wishes to express its grateful appreciation.

Further explained by Dr. Percy H. Walker, U. S. !Bureau of Standards, in his testimony at Trade Practice Submittal at the office of Federal Trade Commission, March 30, 1926 (Transcript, Page 31).

"The gentleman sitting near me has asked me to read from a circular of the Bureau of Standards. I may preface this by saying that THIS IS A PIECE OF INFORMATION FOR WHICH WE ARE INDEBTED TO THE SOAP TRADE. I SUBMIT IT AS A PIECE OF INFORMATION. IT IS AS FOLLOWS:" (Then follows the quotation from Circular No. 62, 1923, Ed. p. 9, quoted above.)

C. P. Long, referred to as a source of information for Bureau of Standards Circular No. 62, is, or was, Chemical director of the Globe Soap Company, Cincinnati, which manufactured or manufactures four brands of "Castile" referred to as "Castile in combination," namely, GLOBE CASTILE, GLOBE LION CASTILE, GLOBE WHITE CASTILE, and LION CASTILE.

The statement above that true Castile is "invariably sold as olive-oil Castile" is a gross error. This statement is undoubtedly due to the regrettable mistake of the revisers of the tenth decennial pharmacopoeia, for the first time in its history of defining Castile soap as olive oil Castile. This gives no warrant for calling other soaps, not made wholly from olive oil, Castile.

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