filled out by the State inspectors leave no detail to be overlooked. The inspector must certify to his chief the condition of the warehouse as to cleanliness of floors, dampness and ventilation of cellar, screens for doors and windows, proper toilet and washroom accommodations for employees, cleanly appearance and freedom from disease of workmen, general tidiness of premises as a whole, storage of eggs and butter separated from that of other foods, storage of all food apart from unclean or malodorous articles, prompt removal of decayed or odorous goods, etc.

Temporary Storage, Leased Rooms and Goods for Export. -Nearly all the statutes recognize the desirability of temporary storage. In fact the usual definition of cold storage makes it applicable only to goods held for thirty days or more. Goods in store, even though held in a cold-storage warehouse, for less than thirty days do not become technically cold-storage goods. In one or two instances where such provision is omitted from the statute (earlier acts) the regulations effective thereunder make provision for temporary storage. The thirty days, too, shows some variation, becoming forty days in Wisconsin and sixty in Nebraska. Temporary storage is in New York further defined as being "the storage of food for the sole use of the occupant, owner or maintainer thereof for consumption by himself or his family or guests." This qualification is hardly needed because such storage is essentially private and is nowhere subject to the cold-storage laws. Refrigerator cars and refrigerated vehicles are also temporary storages, being specifically so defined with some States.

In Massachusetts exists a peculiar definition of "temporary storage." It is contained, not in the statute but in the regulations for that State:

(1) Articles of foods which have been in cold storage without this Commonwealth, the date of original storage of which can not be determined; (2) articles of food which appear to have been previously in cold storage and not bearing any date of original storage; may be placed temporarily in cold storage, and the depositor thereof shall immediately notify the Department of Public Health, and shall request permission to keep such articles

for a definite period less than twelve calendar months. On receipt of this request, the articles will be examined and if found to be in satisfactory condition, permission to retain such articles in storage may be granted.

Such goods are held in temporary storage until tagging is done to correspond with the date for removal as determined by the inspector. The whole regulation is aimed to protect citizens against food coming into the State from those States (such as Indiana and Nebraska) whose law permits removal of storage marks when goods leave the State.

Rooms in the warehouse, or portions of the building, may be under lease to others. When thus sublet, the tenant becomes responsible under the laws for observance of the statutory coldstorage requirements. Reports of the leasing contract, required of the warehouse owner, with necessary details, throws upon the lessee all the obligations as to conduct of the leased accommodations and the contents. Such leases are common with packinghouse storages, who often sublet for general food merchandise a part of their capacity.

At the port cities, foodstuffs designed for export are carried in cold storage, due account of which purpose is allowed in the legislation. More commonly, the statute has overlooked the matter, which has then been covered by regulation. New York's new act contains the most elaborate provision for export foods.

As a rule, separate monthly reports are required of holdings for export, and when withdrawn on export lading, a final report of disposition is made. Occasionally cold storage for export is conducted under a system of permits, which preserve identity of all records and reports for each lot of goods.

Permissible Length of Cold-Storage Period.-Progress has been toward uniformity of enactment. Equally has it tended toward reasonableness and sanity. The first Pennsylvania act held supremacy for drastic requirements, and its neighbor Delaware emulated the distinction for severity (Delaware's statute remains unchanged). The crux of rigid regulation, everywhere, has been the permissible length of the storage period. Great variations have occurred.

Pennsylvania's first statute (1913) set limits as follows:

Delaware placed, unqualifiedly, a 6 months' limit for all foods. Indiana set the limit at 9 months, and that law, like Delaware's has never been revised. New Jersey and New York made 10 months the extreme limit, with the exception of butter in New York which was allowed 12 months. Both these statutes have been revised and brought to the 12 months' standard. The Virginia statute remains at 10 months, but with extension for 2 months possible. The Ohio statute, now effective, permits storage for 12 months for all products except the following, the allowance for each of which is indicated:

The Ohio statute contains a sort of contradiction, which has permitted rather general evasion. It is lawful, in that State, to store "whole carcasses of beef" for twelve months. This makes easy the path to extend the 6 months of the law, and a like allowance for whole carcasses of pork, sheep, lamb, veal, dressed fowl and fish gives the same possibility.

In order that an incorrect impression shall not be gathered from these statements, it should be emphasized that most of these preliminary statutes have since been revised. Present time regulations conform pretty closely to the best thought in the industry, and, interesting to record, almost exactly to the recommendation of the Massachusetts Commission of 1910. Delaware still holds to 6 months; Indiana to 9; and Ohio to the schedule just given. Elsewhere 12 months prevails.

Revision of the early statutes was necessary. The laws defeated their very purpose. They received no more observance in spirit than our obsolete 15-mile traffic ordinances. Delaware's 6 months' limit was wholly unscientific. If it had been rigidly

observed, the people of that State would have been deprived of the major part of the benefits of cold storage. Needless to say, the people have NOT lost these benefits, and the explanation is found in the vagueness of inspection responsibility for the State, together with the proximity of Philadelphia and Baltimore storages which have become refuge for any persecuted Delaware warehouseman. The first Pennsylvania act aroused endless protest over the short allowances for meat and poultry, while the 9 months' time for butter served no purpose.

Eggs, as elsewhere outlined, have received most exact coldstorage attention. It is established beyond question that April and May eggs keep best and longest; June and July eggs most poorly. The best cold-storage practice holds the April egg for post-holidays' consumption, whereas the August egg is moved to market in the autumn and early winter. The original Pennsylvania statute, therefore, upturned the biology of the egg, by legislating the impossible. Had the law been observed, the people of that Commonwealth would have eaten in January and February the eggs of July and August-eggs known to be approaching the unwholesome stage. Trade in eggs would have been forced into unnatural and illogical practices to the injury of consumers, and with no compensation to anyone.

In the matter of time limit, the best practice fixes upon 12 months as reasonable. Such provision is incorporated in the Uniform Act, and this period has become almost universal with the newer legislation.

Extension Beyond First Period. The usual phraseology of statutes with reference to such extension is:

No person, firm or corporation shall hereafter keep or permit to remain in any cold-storage warehouse any article of food which has been held in cold storage either within or without the State, for a longer aggregate period than twelve months, except with the consent of the State Food Commissioner, as hereinafter provided.

The present statutes allow, as the earlier drastic ones did not, some extension beyond the year's limit, subject to specific approval of the proper official. For this consent the wording is:

The State Food Commissioner shall, upon application during the twelfth month, extend the period of storage beyond twelve months for any particular article of food, provided the same is found upon examination to be in proper condition for further cold storage. The length of time for which such further storage is allowed shall be specified in the order granting the permission. A report on each case in which such extension of storage may

I hereby make request for permission to hold in cold storage beyond the twelve months' period which expires....

....

19...., the following articles:

Form 12. Form of Application for Extension of Time to Cover ColdStored Goods in Minnesota

be permitted, including information relating to the reason for the action of the State Food Commissioner, the kinds and amounts of the articles of food for which the storage period was extended, and the length of time for which this continuance was granted, shall be filed, open to public inspection, in the office of the State Food Commissioner, and shall be included in his annual report.

Such extension shall be not more than sixty days; a second extension of not more than sixty days may be granted upon a