TEXAS AGRICULTURAL EXPERIMENT STATION AGRICULTURAL AND MECHANICAL COLLEGE OF TEXAS W. B. BIZZELL, President BULLETIN NO. 241 FEBRUARY, 1919 DIVISION OF FEED CONTROL SERVICE COTTON SEED MEAL B. YOUNGBLOOD, Director College Station, Brazos County, Texas STATION STAFFT ADMINISTRATION B. YOUNGBLOOD, M. S., Director A. B. CONNER, B. S., Vice Director J. M. JONES, A. M., Assistant Director CHAS. A. FELKER, Chief Clerk A. S. WARE, Secretary W. T. BRINK, B. S., Executive Assistant in Charge of Library and Publication . . . . . . . . . . . . . . .., Technical Assistant VETERINARY SCIENCE *M. FRANCIS, D. V. M., Chief H. SCHMIDT, D. V. S., Veterinarian D. H. BENNETT, V. M. D., Veterinarian CHEMISTRY G. S. FRAPS, Ph. D., Chief; State Chemist S. E. ASBURY,'M. S., Asst. Chemist S. LOMANITZ, B. S., Asst. Chemist FRANCES SUMMERELL, B. S., Assistant Chemist WALDO WALKER, Assistant Chemist TOMMIE FRANKLIN, Laboratory Assistant GUS-SIE BROCKMAN, Laboratory Assistant VELMA GRAHAM, Laboratory Assistant HORTICULTURE H. NE S, M. S., Chief S W. S. HOTCHKISS, Horticulturist ANIMAL INDUSTRY J. M. JONES, A. M., Chief; Sheep and Goat Investigations J. C. BURNS, B. S., Animal Husband- man in Charge of Beef Cattle Inves- tigations (on leave) P. V. EWING, M. S., Animal Husband- man in Charge of Swine Investigations C. M. HUBBARD, B. S., Assistant Ani- mal Husbandman W. L. MAYER, Poultryman W. A. DOUBT, Dairyman ENTOMOLOGY F. B. PADDOCK, M. S., Chief; State Entomologist H. J. REINHARD, B. S., Entomologist Assistant Entomologist AGRONOMY A. B. CONNER, B. S., Chief A. H. LEIDIGH, B. S., Agronomist E. W. GEYER, B. S., Agronomist H. H. LAUDE, M. S., Agronomist BLANT PATHOLOGY AND PHYSI- OLOGY J. J. TAUBENHAUS, Ph. D., Chief FORESTRY E. O. SEICKE, M. F., Chief; State Forester PLANT BREEDING E. P. HUMBERT, Ph. D., Chief FEED CONTROL SERVICE F. D. FULLER, M. S., Chief JAMES SULLIVAN, Executive Sec. FARM AND RANCH ECONOMICS THE DIRECTOR, Chief SOIL SURVEY T. CARTER. JR., Chief J. F. STROUD, Soil Surveyor T. M. BUSHNELL, B. S., Soil Surveyor . . . . . . . . . . . . . . Soil Surveyor SUBSTATIONS No. 1. Beeville. Bee County I. E. COWART, M. S., Superintendent No. 2. Troup, Smith County W. S. HOTCHKISS, Superintendent No. 3. Angleton, Brazoria County E. B. REYNOLDS, M. S., Superintendent No. 4. Beaumont, Jefferson County A. H. PRINCE, B. S., Superintendent AARON HARMON, Scientific Assistant o. 5. Temple, Bell County D. T. KILLOUGH, B. S., Superintendent No. 6. Denton. Denton County C. H. McDOWELL, B. S., Superintendent No. 7. Spur, Dickens County R. E. DICKSON, B. S., Superintendent N EFL-Cor February 1, 1919. No. 8. Lubbock. Lubbock County R. E. KARPER, B. S., Superintendent D. L. JONES, Scientific Assistant No. 9. Pecos, Reeves County J. W. Jackson, B. S., Superintendent No. 10. (Feeding and Breeding Substa- tion), College Station, Brazos County J. W. JENNINGS, B. S., Superintendent H. G. WARE, Scientific Assistant No. 11. Nacogdoches, Nacogdoches Co. G. T. McNESS, Superintendent No. 12. Chillicothe, Hardeman County A. B. CRON, B. S., Acting Supt. V. E. HAFNER, B. S., Scientific Asst. No. l4. Sonora, Sutton-Edwards Counties E. M. PETERS, B. S., Superintendent *In cooperation with the School of Veterinary Medicine, A. and M. College of Texas. **In cooperation with the United States Department of Agriculture. CONTENTS Page Decrease in Quality of Cottonseed Meal . . . . . . . . . . . . . . . . . . . . . . . . .. 4 Definition of Cottonseed Meal . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . 5 Standards for Cottonseed Meal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ’ Selling Hulls for Meal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Cottonseed Meal as a Mixed Feed . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 8 The Purchaser Should Know What He Buys . . . . . . . . . . . .2 . . . . . . . . . 8' Patriotism . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. Selling on a Protein Basis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 9 Attitude of the Division of Feed Control Service . . . . . . . . . . . . . . . . . . . .10 What is Adulteration? .c . . . . . . . . . . . . . .* . . . . . . . . . . . . . . . . . . . . . . . . .13 Sale of Low Grade Cottonseed Products not to the Interest of the Consumer . . . . . . f . . . . . . . . . . . . . . . . . . . . . . . . . ; .14 Manufacture of Low Grade Cottonseed Products Not to the Interest of the Manufacturer" . . . . . . . . . . . . . . . . . . . . .2 . . . . . . . . . . 15 Standards in Other States . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17 Some Views of Consumers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..18 Some Resolutions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ; .19 Fighting the Battle of the People . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21 Proposed Legislation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21 Effects of This Bill . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22 What the Legislature Should Do. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -). COTTONSEEDTWEAL F. D. FULLER, Chief, Division of Feed Control Service G. S. FRAPS, Chief, Division of Chemistry For several years some of the Texas cottonseed crushers have been, requesting that the Feed Control Service lower the standards for cottonseed meal. That is to say, they wish to market a product containing more cottonseed hulls, and . still call the product cottonseed meal. The object of the present bulletin is to show the public the significance of such a movement. DECREASE IN QUALITY OF COTTONSEED MEAL The quality of cottonseed meal sold in Texas has been steadily decreasing. This is shown in Table 1, taken from Bulletin No. 189. The productive value decreased from 19.28 in 1907 to 16.98 in 1915, a decrease of 12.5 per cent. Table 1.—Decrease in Value of Texas Cottonseed Meal l I 3 J1 w ‘S "S 2 = 2 E .§ .5 5% éé 3% e § éfi ii 5% . re l Efi E . n. L11 o Z . C: n. l % I C/n (/0 l (/7 I W I I ‘7n 1907——July t0 January I 47.65 I 9.73 6.50 l 23.74 I 41.07 19.28 I 8.8 1909——July to January I 47.41 l 9.13 7.66 , 23.37 l 40.87 l 18.78 I 11.5 1911——July to January I 46.59 8.79 7.78 I 24.60 I 40.16 18.63 I 12.0 1913~—July to January I 45.14 I 8.51 9.52 l 24.05 I 38.59 I 17.86 I 16.3 1915—-July to January I 45.40 I 8.08 8.61 25.14 538.83 I 17.56 14.0 1917—cottonseed meal .I I I I l I Average . . . . . 43.32 l 8.02 I 10.74 l 25.51 l 36.71 17.27 I 19.4 1918—-cottonseed meal .I I I I I Average . . . . .I 43.21 I 7.60 l 11.30 I 25.98 I 36.63 I 17.10 I 20.7 Cracked Feed No. 4. . . . .I I I I I 1917-18 average..I 41.84 I 6.50 I 12.01 l 26.92 l 35.4 16.35 I 22.5 Cracked Feed No. 5. . . . .I I I I , I I 1917-18 average..I 39.88 I 6.32 I 12.76 I 27.78 I 33.6 l15.85 24.5 I Cracked Feed No. 6.... .I I I I I I 28.6 1917-18 average..l 37.73 I 6.91 I 14.44 I 27.63 31144 l 15.87 Feed No. 4 5.1% excessl I I hulls . . . . . . . . . . 41.2 I 5.00 13.9 I 27.00 I 34.7 l.15.2 I 27.3 Feed No. 5 12.1% excessl I I I hulls . . . . . . . . . . .l 38.5 I 5.00 I 15.6 I 28.1 I 32.2 15.00 I 31.5 Feed No. 6 17.5% excessl I I I I I hulls . . . . . . . . . . 36.00 I 5.00 I 17.7 I 28.5 I 29.8 14.3 I 35.7 5 I‘. COTTONSEED MEAL 5 i; The feeders who think they are getting the same quality 0f p‘ feed as formerly are naturally deceived, and are disappointed in the results of the feeding. 5 The enforcement of the Texas feed law is the only thing Ithat prevents a further decrease in the quality of cottonseed gmeal. The natural tendency is to reduce the quality to as “low a point as will be permitted. DEFINITION OF COTTONSEED MEAL , Cottonseed meal is defined as the pressed decorticated »kernels of cottonseed, free from excess of hulls. As a matter of fact, many cottonseed crushers put in as much hulls as the law permits. Some cottonseed crushers wish to put all the hulls into the product and still call it cot- tonseed meal. The consumer of cotton seed meal prefers to lmeal prices for hulls. Cottonseed meal containing more than a moderate mount of hulls, is really a mixed feed. It is a mixture of the ernel residue, which has a high feeding value, and of hulls, hich have a very 10W feeding value. It is thus important that a line be drawn beyond Which a he product containing too much hulls can not be called cot- 0n seed meal. Practically since 1907, this line has been rawn at 43 per cent in Texas. This standard has been es- wablished by custom and usage and accepted by crushers and eeders. V We should continue to draw the line at 43 per cent. A ottonseed product containing less protein should not be per- I itted to bear the name of cottonseed meal or cake. STANDARDS FOR COTTONSEED MEAL The Texas standard for cottonseed meal from 1907 to ‘A 916 was that it should contain not less than 50 per cent fiotein and fat combined, and not more than 9 per cent crude 1 er. ’ On February 2, 1916, Director Youngblood agreed with Q committee of the Texas Cottonseed Crushers’ Association i‘ at cottonseed meal should contain not less than 44 per cent ' rotein, or not less than 51 per cent protein and fat, and not ore than 11 per cent crude fiber. This definition was adopt- d by the Cottonseed Crushers’ Association at San Antonio in ay, 1916. The crushers were not satisfied with this agree- ent, and the following agreement was adopted later: A “We, the undersigned, acting for and in behalf of the exas Cottonseed Crushers’ Association, the Cattle Raisers’ ssociation of Texas, and the Sheep and Goat Raisers’ Asso- ‘buy the meal and hulls separately, as he does not care to pay A 6 TEXAS AGRICULTURAL EXPERIMENT STATION ciation of Texas, have come to the“ following understandin with the Feed Control Service on this 20th day of July, 191 at the Chamber of Commerce, Fort Worth, Texas: _ _ J ",“lt is agreed that the following shall be the definition o" cottonseed meal: “Cottonseed meal is composed of the decorticated kernel of cottonseed, free from excess of hulls and other foreig r, materials. a sale in this State—— ‘ _ ; “Choice Cottonseed Meal shall contain not less than per cent of protein, not less than 7 per cent of fat, and no more than 9 per cent of crude fiber. i “Prime Cottonseed Meal shall contain not less than per cent of protein, not less than 6 per cent of fat, and no a more than 10 per cent of crude fiber. - “Ordinary Cottonseed Meal shall contain not less thani 43 per cent of protein, not less than 6 per cent of fat, and not more than 12 per cent of crude fiber. j “Cottonseed Feed Number Four shall contain not lessi than 41.20 per cent of protein, not less than 5 per cent of fat, and not more than 14 per cent of crude fiber. “Cottonseed Feed Number Five shall contain not less‘: than 38.50 per cent of protein, not less than 5 per cent of fatjf and not more than 18 per cent of crude fiber. “Cottonseed Feed Number Six shall contain not less than 36 per cent of protein, not less than 5 per cent of fat, and not ; IYIOPG than per cent of crude fiber. ' i “Cottonseed Cake shall correspond to cottonseed meal in ; composition and as to standards. '. _ “It is understood. that the standards for cottonseed feeds - numbers Four, Five and Six shall be the same Whether ground _ or cracked. b , “Committeemen for the Texas Cottonseed Crushers’ Asso- ciation: C. C..Littleton, P. S. Grogan, Ed. Woodall. - “Committeemen for the Texas Cattle Raisers’ Associationze F. S. McFarland, A. C. Williams, E. B. Spiller. 7 “Committeemen for the Texas Sheep and Goat Raisers’. Association: B. M. Halbert, Ed. L. Mears, James B. Murrah. “Accepted—B. Youngblood, Director, Texas Agricultural Experiment Station.” These standards were also adopted by the Texas Cotton- seed Crushers’ Association in May, 1918. In spite of these agreements, a committee of the Texas Cottonseed Crushersl. Association, appointed for another purpose, requested theft COTTONSEED MEAL 7 Feed Control Service and a commitee ofthe Cattle Raisers’ Association of Texas to agree to lower the standard for cot- tonseed meal to 36 per cent protein. On September 19, 1918, certain cottonseed millers, par- ticularly in South Texas, sent out a circular letter to the trade suggesting that out-of-state buyers be given preference over purchasers residing in the State. This was done with the evident purpose of forcing the Division of Feed Control Ser- vice to lower the standards for cottonseed meal and cake, 1n- asmuch as the standards for these products in other states are not so high as in Texas. A copy.- of this circular letter follows: I Houston, Texas, Sept. 19, 1918. TO ALL MEMBERS OF THE SOUTH TEXAS COTTON . SEED OIL MILLERS ASSOCIATION. ’ Gentlemen: At a meeting of the Texas Cottonseed Crushers’ Asso- ciation held in Dallas recently, I was appointed chairman of a Committee consisting of Mr. C. N. Thatcher of Wills Point, Mr. E. H. Young of Dallas and myself, to confer with the Texas Feed Control about sampling and analyzing carload ship- ments of cottonseed meal and cake when sold to Texas buyers. Your committee met with Mr. Fuller and Mr. Sullivan of the Feed Control and Mr. Spiller and Mr. Todd of the Texas Cattle Raisers’ Association in the office of the Texas Cattle Raisers in Ft. Worth on Tuesday, Sept. 17. An agreement was entered into regarding sampling at mills, which I think will be satisfactory to the mills. Secretary Gibson’s office will send you full details within the next day or two. After this agreement was entered into the Committee took up with the Cattle Raisers and also the Feed Control Rep- resentatives the question of changing the present Feed Con- trol rules so as to allow us to sell 36 per cent or over protein meal or cake under its proper name instead of having to sell‘ it as “Cottonseed Feed” or “Meal and Hulls.” As you know, the Texas Feed Control is the only one in the United States that requires us to misbrand our products and sell them under the stigma of adulteration. We feel that if the Cattle Raisers would insist on the Feed Control changing its rules it would be done, but I regret to report that the Cattle Raisers refused to do this. - In all States but Texas our 36 per cent to 41 per cent cake and meal is sold as “Prime Cottonseed Meal or Cake” and this year at least the out of State buyers are anxious to get every pound We will make; they will furnish you with tax tags free of cost to you and will pay brokerage and exchange so that the Government price will be net to you. 8 TEXAS AGRICULTURAL EXPERIMENT STATION 'I therefore suggest that in making sales of your cake V . and meal from now on you instruct your broker to sell only to out of State buyers where products will be sold under their proper classification. And to keep these instructions in force until our Feed Control sees fit to change its obnoxious rules. You are required by our Government to cut at least 145 lbs. of lint, and more if possible, so that it is now no longer possible to make 43 per cent cake but our 39 per cent to 41 per cent cake and meal is preferred by feeders in other States so we have no fear of not having an ample market to dispose of all we can make. A A Yours very truly, (Signed) R. F. ISBELL, Secretary-Treasurer. SELLING HULLS FOR MEAL As seen above some Texas cottonseed crushers want to call a product containing 36 per cent protein “Cottonseed Meal.” ‘ This means that they would place 82.5 pounds of meal and 17.5 pounds of hulls in a 100 pound bag, and call _ the mixture “Cottonseed Meal.” .Why do they wish to do this? There is nothing to pre- vent them from manufacturing and selling ‘such a product in Texas, provided they call it “Cottonseed Feed No. Six.” The answer is simple: the purchaser who buys Cottonseed Feed No. Six knows he is buying meal and hulls and pays accord- ingly. But if “Cottonseed Feed No. Six” is sold under the name of “Cottonseed Meal” the purchasers are willing to pay more for it, for they would think they were buying cotton- seed meal,‘ especially the poorer and more ignorant people. Therefore, the cottonseed crusher wishes to sell Cottonseed Feed No. Six under the term “Cottonseed Meal” so that he ‘Will induce the purchaser to pay more money for the same product. Do Texas farmers want to pay more for cottonseed feed by permitting the crushers to call it cottonseed meal? COTTONSEED MEAL AS MIXED FEED The decrease in quality of cottonseed meal previously shown is partially due to increased hull content. If some of the cottonseed crushers had their Will, there would be no limit to the amount of hulls present in meaL-until all the hulls were in the meal, and none sold alone. Cotton-- seed meal would then be a mixed feed, what it is now to some extent. THE PURCHASER SHOULD KNOW WHAT HE BUYS Cottonseed crushers say they tell what their product is when they guarantee the protein in it. But consumers have a COTTONSEED MEAL 9 definite thing in mind when they buy cottonseed meal. If they are furnished with goods of a lower grade they are de- frauded. The term “Cottonseed Meal” means a definite ar- ticle to the consumer, fixed by years of usage. ' The consumer has a right to know what he buys. If he buys cottonseed meal or hulls and meal he should know it. He should not be sold cottonseed feed camouflaged as cotton-- seed meal. PATRIOTISM At a time when Texas was short of feeds, when the price of cottonseed meal was fixed by the Government, when such action was distinctly contrary to the interest of the Govern- ment in the war, some cottonseed crushers recommended that cottonseed products be not sold in Texas but shipped outside the State because cottonseed feed containing 16 per cent more hulls than cottonseed meal may not be sold as cottonseed meal. The price fixed was the same both within and without the State, but the attempt was made to deprive the Texas people of needed feed, to force a change in name that would prevent the consumer from knowing how much hulls he was getting. In justice to the crushers it must be said that most of them condemned this action. ' SELLING ON A PROTEIN BASIS Some cottonseed crushers claim that they sell on a pro- tein and fat basis, therefore the name is not of importance and so they should be allowed to call the product cottonseed meal, without regard to the hull content. If the name is not of importance, then the cottonseed crushers should not object to calling the product containing less than 43 per cent protein “Cottonseed Feed” and stating the percentage of hulls present. These men really say that it does not matter what the product is called, as long as it is called cottonseed meal. It is true that large quantities of cottonseed products are sold upon a protein and fat basis, and adjustment made in the price according to the analysis. The man who buys a carload can easily protect himself by means of an analysis. But there are large quantities of cottonseed products sold in quantities of from one sack to several tons. These pur- chasers buy by the name rather than by the analysis. r They l cannot afford to have an analysis made in order to secure a rebate. It is these purchasers that the feed law must be especially careful to protect. The term “Cottonseed Meal” has become standardized by usage, and thousands of farmers and dairymen look at it as a definite product, as indeed it is. If the tag reads “Cottonseed Feed” and the amount of excess 10 TEXAS AGRICULTURAL EXPERIMENT STATION hulls is stated in connection with the analysis, these small purchasers are placed 0n notice as to the character of the goods purchased. If the standards should be lowered, these purchasers would believe that they were buying better goods than they really were, and they would suffer. When a carload of cottonseed meal is sold, found to be below guarantee, and a rebate paid to the purchaser, it does not always follow that the consumer gets the, benefit. In many cases such cottonseed meal is retailed in small lots at the usual price, and the merchant gets the rebate as a special profit, while the consumer pays the bill. If, however, the tags are changed to conform with the analysis, then the con- sumer may get the rebate, or at least a part of it. Cottonseed crushers who sell in carload lots and deal little with the small consumers, are in many cases utterly un- able to see the injustice worked on the consumer when the goods are improperly named or improperly tagged. In many cases of such impropertagging the crusher pays the rebate but the actual consumer never gets any of it, because the goods are claimed on the tag to be better than they really are. The same applies to the improper use of the term “Cot- tonseed Meal.” The crusher may sell upon a protein andfat basis, and derive only a small benefit from the use of a mis- leading name, but the "consumer, who is accustomed to a bet- ter article, pays a price for the name, which may go largely into the pockets of the “middleman.” ATTITUDE OF THE DIVISION OF FEED CONTROL SERVICE The attitude of the Feed Control Service toward cotton- seed meal and all other feeds, is that the consumer shall have what he buys. This is the object of the Texas feed law. The following extract from an editorial in “Flour and Feed,” November, 1918, illustrates this attitude. “Our theory for the purpose of argument is that if any manufacturer is such a fool as to put ivory nut turnings into a a mixed feed for animal consumption, he should be permitted to do so, if he properly posts the man who buys the feed that he has done so. This is the crux of the whole proposition. The tag on the bag of feed should be an honest and complete description of what the feed is made of. It is to this end that all legislation on the feed business should be directed, backed up, of course, by legislation to make sure that this end is car- ried out. If the manufacturer tells just exactly what his feed is made of and guarantees the chemical analysis, and the in- spection system that is followed makes sure that this is done, there will be less room for misrepresentation and fraud in connection with the merchandising of these articles than there is today in connection with almost anything of any description COTTONSEED MEAL 11 that the public buys. In other Words, under such a plan there could be no misrepresentation at all. Misrepresentation then Would be flagrant violation of laW and would be easily punishable.” This is to say, the names of the feeds should show With- out a doubt their exact character. The percentage of all the ingredients Which go into a mixed feed should be stated. The Texas law does not go as far as this, but the Writers believe that all laWs should contain a provision to this effect. Doubt- ful, ambiguous, or misleading names should not be used for any feed; the name should show Without doubt What the feed 1s. The Division of Feed Control Service enforces the Texas feed laW and suggests names, makes definitions and formu- lates standards in accordance With the spirit of the law, aided, of course, by the most reliable chemical, manufacturing and and feeding data available. We use names Which are not misleading. The name “Cottonseed Meal” is one that has long been in use, and the quality of cottonseed meal is higher in Texas than in any other State. For adulterated products, We choose appropriate names and designations. The trouble With some of the Texas millers is that they endeavor to overcome the judicial tendencies of the Division of Feed Control Service With sophistry and influences Which do no credit to the Texas Cottonseed Crushers’ Association. Most of the millers know, and the rest of them Will in time learn, that fair play is the best policy. This, the Division of Feed Control Service extends to all millers in all times. The Division of Feed Control Service has to consider the interests of all buyers or consumers of feeding stuffs, and the relation of the feed manufacturing business to the economic condition of society at large. The entire problem is one which should be governed by plain economic principles, and not the opinion either of manufacturers or consumers, both classes of which are biased Witnesses. The millers have not yet suc- cessfully demonstrated the benefit to society at large for them to mix cottonseed hulls With cottonseed meal and sell the mix~ ture as cottonseed meal. The Feed Control Service believes that they will never be able to do so. It is not right in dealing with fellow men to practice de- ception in any form, or to misrepresent anything which may be placed upon the market for sale. Honesty and integrity must stand out very prominently in all business relations if any degree of prosperity is attained. One may desire success and Wealth, but they must be obtained only through legitimate means. At no time is it right. from a moral standpoint, to mix oat hulls With corn and sell the product as corn and oat 12 TEXAS AGRICULTURAL EXPERIMENT STATION chops. It is ethically wrong to adulterate wheat shorts with ground corn cobs and place the mixture 0n the market as “Choice Gray Shorts.” At no time is it right t0 adulterate cottonseed meal with twenty-five per cent of cottonseed hulls and sell the product as cottonseed meal. That is, it is con- trary to the first principles of ethics. It would be just as proper for a dairyman to sell water for cream as for a feed manufacturer to put on the market a mixture of cottonseed meal and cottonseed hulls and label the package as containing “Prime Cottonseed Meal.” There is nothing injurious in cot- tonseed hulls; they contain a small amount of protein and fat, and if anyone wants to buy cottonseed meal and hulls mixed together, he should be accomodated, but when he wants cottonseed meal he does not want an adulterated ar- ticle. a Texas cottonseed products are the highest in quality in the world, and the millers who would wilfully adulterate them and bring them to the low levels of other states which are unable to make products of Texas’ quality are working against the best interests of the milling industry in Texas and the best interests of the State itself. Our soils and climatic conditions are such that Texas is renowned throughout the world as producing the highest quality of cottonseed meal. In the Eastern states, however, cottonseed runs high in oil and correspondingly low in protein. Because of the extensive advertising which has been given to the high protein content of Texas cottonseed meal, and be- cause, in part, of the general shortage of protein concentrates throughout the United States, due to war conditions, there has been an unusually heavy demand for Texas cottonseed meal in other states, particularly in the Northwest, Central West and the East. ' At a recent conference with millers, many complained that it was difficult to comply with the rules of the War Indus- tries Board requiring them to cut 145 pounds of linters from a ton of seed, and at the same time producing cottonseed meal containing 43 per cent of crude protein. It was brought out in the discussion that this could be done providing the mills were equipped with machinery for the purpose of producing high-grade cottonseed meal and cake, as many of the modern mills are so equipped at the present time. The records of the Division of Feed Control Service show that many mills in Texas have succeeded in making high- grade meal in the face of the Federal requirements, and other millers might have done the same had their mills been so equipped. There is no doubt that many of the mills now mak- mg low-grade meal have done so of their own volition to sup- ply a patronage which they have developed for low-grade COTTONSEED MEAL 13 products. The Division of Feed Control Service recognizes this as a temporary problem of some mills not properly equip- ped, but even with these it is one of only a temporary nature and which has been obviated now that the war 1s over and the demand for linters has decreased to normal. The Feed Con- trol Service, therefore, has declined to lower the standards for cottonseed products, feeling that the present standards, taking into consideration both the manufacturer and consum- er, are the least unfair and the most equitable that could be promulgated. The Division of Feed Control Service realizes that there is a number of factors, any one of which may occasion fluctu- ations in the quality of cottonseed meal. Some of these fac- tors are seasonal in nature, while others involve the efficiency of the mill machinery and even the miller himself. We do not deem them to be of sufficient importance to justify period- ical lowering of standards in compliance with requests which are constantly coming from the millers, neither are we per- mitted to do this in view of the scientific evidence presented in this bulletin. It may be stated in this connection that equally urgent requests are made upon the Division of Feed Control Service by the consumers of feeding stuffs throughout the State for either maintaining the present standards or raising them rath- er than lowering. The Feed Control Service must hear all alike and make rulings in accordance with the law and the facts available. WHAT IS ADULTERATION ‘? Some cottonseed crushers say that to call a cottonseed product “cottonseed feed” and state the percentage of excess hulls, is to place the stigma of adulteration upon it. The Texas law reads as follows: “For the purpose of this act, a feeding stuff shall be deemed to be adulterated if it contains any sawdust. dirt. dam- aged feed, or any foreign matter whatever, or if it is in any respect not what it is represented to be; or if any rice hulls or chaff, peanut shells, corn cobs, oat hulls, or other similar sub- stances of little or no feeding value are mixed therewith; pro- vided, that no wholesome mixture of feeding stuffs shall be deemed to be adulterated if the true percentage of constitu- ents thereof is plainly and clearly stated on the package, and made known to the purchaser at the time of the sale.” ‘ As inferior cottonseed meal contains an excess of cotton- seed hulls, it would be adulterated under the Texas law if the percentage of hulls was not stated. It would also be adulterated under the Texas law if rep- resented to be cottonseed meal. when it contains so much hulls that it is not cottonseed meal, but cottonseed feed. 14 TEXAS AGRICULTURAL EXPERIMENT STATION But the law expressly says that a feeding stuff is _not adulterated if the true percentage of constituents is plainly and clearly stated 0n the package and made known t0 the purchaser at the time 0f sale. Therefore, cottonseed feed 1S not adulterated if the percentage of cottonseed hulls is stated. But if termed cottonseed meal and the percentage of hulls were not stated, the product would be adulterated un- der the terms of the law, because it Would not be the product which custom and usage have established to be cottonseed meal in Texas. The attitude of the courts toward such mat- ters is shown by the following extract from the charge of Federal judge in a case concerning water-ground meal, brought under the Federal law. “As matter of law I charge you that a man when he pur- chases an article, has a right to buy whatever he pays his money for; it may be a pure fancy on his part, and it may be the veriest whim on his part, but if he stipulates in the con- tract that he is to buy certain specified articles or an article prepared in a certain specified way, and that is the contract and the agreement, and he pays for it, then he is entitled to have it, although the result may be that he chooses to buy an inferior article at a higher price, he has the right to have what he pays for. Therefore in this case the question is not as to the character of the substance in here, not any question of moral turpitude, that defendant only furnished an inferior article, that does not come in; the question is as to whether these sacks of meal contained the article that they were stated to contain, or is the statement on them calculated to mislead and deceive the person, that is, the consumer, in buying the article that he intends to buy.” SALE OF LOW GRADE COTTONSEED PRODUCTS NOT TO THE INTEREST OF THE CONSUMER While the policy of the Feed Control Service is not to object to the sale of any wholesome feeding stuff, provided. that it is properly named and labeled, yet it must be observed that the manufacture of low grade cottonseed products is not to the public interest. It will be shown that it is not to the advantage of the manufacturer to manufacture such feeds, and it is frequently not to the advantage of the consumer to buy them. The latter point will be discussed first. A 36 per cent protein cottonseed product could be made fr0.m 2000 pounds of 43 per cent protein cottonseed meal and 400 pounds of hulls, in round numbers. 2000 lbs. meal contains 850 lbs. protein. 400 lbs. hulls contains 12 lbs. protein. 2400 862 Per cent protein 36.3. COTTONSEED MEAL ~ 15 The cottonseed meal is a concentrated feed; the hulls are a roughage, and have a lower feeding value than any hay and many straws. Many farmers and dairymen have all the roughage they need, even more than they need. Roughage, goes to Waste on many farms. But when a farmer buys 36 per cent cottonseed feed, for every ton of cottonseed meal he gets, he is compelled to buy 400 pounds of cottonseed hulls. He must buy something he may not need and may not want. This is not to the public interest. In buying this 400 pounds of hulls to the ton of cottonseed meal, the farmer must pay for the sacks to hold it; he must pay the freight to his station at feed rates, Which is a higher rate than hull rates. He must pay for the additional cost of handling at the mill, and he must pay a profit to the manufac~ turer and retailer. All this on something which he may not need to buy at all. Even if he needs the hulls, it would be more to his interest to save the sacks, save the difference in freight rates, and save probably a larger profit, by buying the hulls unmixed. Of course, if the consumer, not knowing the amount of hulls in the cottonseed feed, pays a higher price for it than he would for the meal and hulls that it would take to make it, he suffers by paying an unreasonable price. This he must either take as a loss, or pass on to the purchaser of the milk, meat, or other farm products obtained from the cottonseed meal. Part of the profit may go to the oil mill, but a large part goes to the retailer. The foregoing discussion with reference to 36 per cent cottonseed feed applies likewise to the higher grades of cot- tonseed feed, though to less extent. MANUFACTURE OF LOW GRADE COTTONSEED PRO- DUCTS NOT TO THE INTEREST OF THE MANUFACTURER The manufacture of low grade cottonseed products is not altogether to the interest of the manufacturer. The Food Administration fixed the price for cottonseed meal at $57.00 per ton on a basis of 43 per cent protein, and $1.00 less for each per cent less protein. The price for hulls was fixed at $20.00 per ton. At these prices, the manufacturer making 36 per cent protein meal would lose money. In addition to the cost of meal and hulls, he will lose about 6 per cent oil in the hulls, and would need four additional bags. 16 . TEXAS AGRICULTURAL EXPERIMENT STATION COST OF MEAL 2000 lbs. 43 per cent meal . . . . . . . . . . . . . . . .$57.00 400 lbs. hulls . . . . . . . . . . . . . . . . . . . . . . . . .. 4.00 4 bags at 20 cents . . . . . . . . . . . . . . . . . . . . . . . . .80 24 lbs. oil in the hulls at 15 cents . . . . . . . . . . . 3.60 Total cost . . . . . . . . . . . .$65.40 2400 lbs. feed at $50.00 per ton . . . . . . . . .. 60.00 Loss . . . . . . . . . . . . . . . ..$ 5.40 The loss of oil could be avoided by adding the hulls to the cake after the oil-has been expressed from them while it is being ground. If the hulls are left inwith the meal they will retain oil, with the approximate results above stated. The manufacturer may either take care of this loss or pass it on to the consumer, or to the farmer from whom he buys the seed. This can be done only by making the consum- er pay more for the meal and cake than it is really worth, or by paying the farmer less for his seed than it is really worth. It is not practical for the cottonseed crusher to manufac- ture 36 per cent protein feed from Texas seed, unless it is made by adding hulls directly to higher grade cake or meal. When cutting 145 pounds linters per ton of seed, as re- quired by the War Industries Board, some mills had difficulty in making 43 per cent protein meal. That is no reason for not letting the consumer know what product he is buying. The writers believe that the best results in the extraction of oil are secured when 43 per cent protein meal, or better, is made in Texas. If more hulls are present in the cake, they absorb oil and reduce the amount expressed. It is a question whether the manufacture of lOW grade cottonseed products as a general thing would not be to the detriment of the industry as a whole. It is the desire of some cottonseed crushers to put all the hulls in the product, and sell it as cottonseed meal, if permitted. The United States mar- ket for Texas cottonseed meal is probably not the Northeast, where it comes in competition with cottonseed from the other Southern states, that have the advantage of a shorter haul; but to the North, West and Northwest, where transportation conditions favor Texas products. Concentrated products in general justify longer hauls, than less concentrated products. Transportation costs are less per unit value. High grade cottonseeed meal should tiheréefore find more distant markets than the low grade pro- uc s. COTTONSEED MEAL 17 When a concentrated product is reduced by means of lOW grade materials, the transportation costs and other expenses connected with hauling, are likewise increased. The cost per unit of feeding value is thus increased. If this feed comes in competition with more concentrated feeds in the same market, it is at a disadvantage to the extent of the in- creased cost, and it is liable, in the long run, to suffer from the competition. There may be a temporary advantage to the manufacturer, as to the middle man, in lowering the grade, but this temporary advantage may be more than offset by the permanent disadvantage under which the feed labors. To put the matter in another way, it is not economical to ship cottonseed hulls or similar low grade feeds long distan- ces. The transportation costs are too large in proportion to the feeding value. There may be temporary emergencies. when roughage is high, when such feeds may be shipped long distances, but under normal conditions it does not pay. It is still less economical to ship cottonseed hulls mixed with cottonseed meal such distances. The freight rate on the hulls in such a mixture is higher than for the hulls alone. There is the cost of bags and the greater cost of handling. A temporary advantage may result from such a mixture, under some conditions, but the matter will eventually be adjusted so that the industry bears the burden of the increased cost. The general manufacture of low grade cottonseed pro- ducts would thus appear contrary to the best interest of the industry. STANDARDS IN OTHER STATES Some Texas cottonseed crushers claim that A they are placed at a disadvantage because other states permit the sale of lower grade products as cottonseed meal. Texas cottonseed crushers are not placed at any disad- vantage in manufacture. They can make any wholesome product that they desire. The only restriction is that they must correctly name and label their products when sold in, Texas. They are not at a disadvantage in Texas as all mills sell under the same names. They are not at a disadvantage outside the State, as when Texas cottonseed products are sold outside the State they do not come under the Texas feed law, but are subject to the requirements of the law of the state or country to which they are shipped. They then meet the competition of the other states on an equal basis. The lowest standard for protein in cottonseed meal is 36 per cent fixed by law for South Carolina. North Carolina and Georgia require 38.62 per cent (See Bulletin No. 189). In fixing an interstate standard, 36 per cent was taken, as the 18 TEXAS AGRICULTURAL EXPERIMENT STATION product of South Carolina could not be excluded from inter~ state commerce. The seed grown in South Carolina and other Eastern states is lower in protein and will not make the same grade of cottonseed meal as Texas seed. The following table is taken from the report of the committee on cottonseed meal of the Association of Feed Control Officials of the United States. The meals are calculated ‘from the average analyses of seed examined. Table 2._Hypothetical meals calculated to 11 per cent crude fiber l l l l l l l l State Nitrogen-free Extract 2 l a l l, l "a l é r a i 2 l a :2 A is l < _ l l ‘C/r l ‘76 l (j/(t l ‘Yr: l C/o North Carolina .l 8.00 l 38.62 l 7.00 11.00 ' 29.13 l 6.25 South Carolina .l 8.00 l 38.32 7.00 11.00 29.66 l 6.02 Georgia . . . . . ..l 8.00 l 39.64 l 7.00 l 11.00 28.68 l 5.68 Alabama 8.00 l 39.53 l 7.00 l 11.00 28.49 l 5.98 Tennessee . . . . .l 8.00 l 40.52 l 7.00 l 11.00 26.82 l 6.66 Arkansas . . . . ..l 8.00 l 40.92 l 7.00 11.00 26.85 l 6.2:; Oklahoma 8.00 l 43.50 7.00 l 11.00 - 25.37 l 5.13 North Texas ....l 8.00 l 43.02 l 7.00 - 11.00 25.76 l 5.12 South Texas....l 8.00 l 43.74 l 7.00 l 11.00 l 24.89 l 5.37 Average l 8.00 l 40.99 l 7.00 l 11.00 l 27.18 l 5.83 It is seen that when Texas meal contains 43 per cent pro- tein with 11 per cent crude fiber, North Carolina’s contains 38.62 per cent and Georgia’s 39.64 per cent. But crude fiber means hulls; thus with equal hull contents, Texas is on a par- ity with North Carolina and Georgia in the quantity of hulls permitted in meal. While the quantity of protein is different the quantity of hulls is approximately the same. South Carolina apparently permits more hulls, but some of its seed may be poorer in quality than the sample examined. Oklahoma permits more hulls than Texas. SOME VIEWS OF CONSUMERS The following telegrams present some views of consum- ers: “Farmers, ranchmen and bankers request if quality cot- tonseed meal is changed that protein should be raised instead of lowered.” “Crawford,” “Spur, Texas.” COTTONSEED MEAL 19‘ “Dallas county dairymen and other cottonseed meal con- sumers unalterably opposed to further reduction of protein content of cottonseed meal. They think forty-three per cent is as low as should be permitted Wherever it is an advantage to mixture to add hulls consumer prefers to do mixing.” ' “C. O. Moser,” “Dallas, Texas.” “We want unadulterated cottonseed meal high in protein. We have plenty of roughage.” “C. P. Deadler,” “Angleton, Texas.” “Farmers and stockmen here all prefer high grade meal and cake. No one Willing for mixture meal and hulls sold as cottonseed meal. Low protein content cake and meal not sala- ble. Enter protest against adulteration and misbranding.” “R. P. Elrod,” “San Saba, Texas.” “Feeders prefer high grade meal. Not willing to allow adulteration and misbranding to extent of allowing mixtures of meal and hulls to be sold as cottonseed meal.” “B. D. Black,” “Brady, Texas.” SOME RESOLUTIONS RESOLUTION OF AMERICAN NATIONAL LIVE STOCK ASSOCIATION RESOLUTION NO. 15. Demanding High Standards of Cottonseed and Other Animal Food Products. “WHEREAS, for the past few years a number of the manufacturers of cottonseed products have been gradually decreasing the value of these feed stuffs by the addition of more cottonseed hulls; and » “WHEREAS, the Interstate Cottonseed Crushers’ Association re- quested the Association of Feed Control Officials of the United States to lower their standards for cottonseed meal, and introduce a new and in- ferior grade of meal, which request was refused; and “WHEREAS, the Feed Control Service of Texas has consistently held the position that Texas cottonseed products should not be made in- ferior or equal to the average for other states by lowering the standards to the level of those states; and “WHEREAS, the Director of the Texas Experiment Station has ruled that the lowest quality of Texas cottonseed meal shall be known as “Prime,” and the standard shall be 51 per cent. of protein and fat com- bined, with a minimum of 44 per cent. for protein and not more than 11 per cent. of crude fiber, and that any deficiency in percentage of fat may be made up by an additional percentage of protein, and that cottonseed products inferior to the standard for “Prime” shall hereafter be known as “Cottonseed Feed” or “Cottonseed Meal and Hulls”, which definition Lvas adopted by the Texas Cottonseed Crushers’ Association; therefore e it 20 TEXAS AGRICULTURAL EXPERIMENT STATION “RESOLVED, that the American National Live Stock Association, in convention assembled at Cheyenne, Wyoming, January 18-20, 1917, express its appreciation to the Association of Feed Control Officials of the United States and to the Feed Control Service of Texas for the firm stand which they have taken for legitimate standards for cottonseed products, as Well as other feeding stufls; and be it further “RESOLVED, that the American National Live Stock Association encourage and support in every possible manner the movement, with a view to maintaining the highest standards for cottonseed products, as well as other feed stuffs, consistent with the inherent quality of said raw pro- ducts, With efficiency in milling, and with the interest of the consumers of the United States; and be it further “RESOLVED, that a copy of these resolutions be sent to Mr. Philip H. Smith, secretary-treasurer of the Association of Feed Control Officials of the United States, Amherst, Massachusetts; to President Charles Du- Bose of the Texas Cottonseed Crushers’ Association, Alice, Texas, and to Hon. James E. Ferguson, Governor of Texas, Austin, Texas.” RESOLUTION OF THE CATTLE RAISERS’ ASSOCIATION OF TEXAS “WHEREAS, the Feed Control Service, in accordance With facts obtained by investigation of feed and feeding problems, maintains the highest standards of quality for cottonseed meal, cake and other feeding stufis sold in this State, to be found in the country, and “WHEREAS, during the past winter when the members of this Association were confronted with the momentous problem of wintering their live stock in the face of a prolonged drouth and a great; scarcity of feeding stuffs of every kind, the Feed Control Service rendered an in- valuable service in a most satisfactory manner by conducting analysis of each car of meal and cake, and by acting as arbiter between the manu- facturer and feeder as to the price which should be paid on the basis of protein content. “THEREFORE, BE IT RESOLVED, that the Cattle Raisers’ Asso- ciation of Texas at its Forty-second Annual Convention in Dallas, Texas, March 19, 20, 21, 1918, go on record as opposed to any interference whatsoever with the present administration of the Pure Feed Law", or to its consolidation with any other branch of the State Government at this time, it being the experience of the Association that those having the technical knowledge derived from the investigation of feed and feeding problems are best qualified to enforce the provisions of the Pure Feed Law without fear or favor, and in a manner consistent with the best in- terest of the agricultural and live stock business of the State; and be it “RESOLVED, further that a copy of this resolution be sent to Gov- ernor Hobby and to each member of the Senate and House of Repre- senatives.” RESOLUTION ADOPTED BY THE EXECUTIVE COMMITTEE OF THE SHEEP AND GOAT RAISERS’ ASSOCIATION OF TEXAS “WHEREAS, ordinarily the ranges of Texas produce crude fiber in the form of grasses, brush, and other roughages, in abundance, and “WHEREAS, in case of shortage of such roughages in periods of long drouth it is more economical for us to buy our crude fiber unmixed with concentrates. and “WHEREAS, continously strong pressure is brought to bear upon the Feed Control Service of the State of Texas by millers, jobbers, and out-of-state brokers, to force this Service to permit the adulteration of what_we know to be good cottonseed _m_eal with cottonseed hulls, and to permit the use of names on tags containing such mixtures as are mislead- ing to the farmers and stockmen of this State; therefore be it COTTONSEED MEAL 21 “RESOLVED, that the Executive Committee of the Sheep and Goat ’ Raisers’ Association of Texas, in meeting assembled at Del Rio, Texas, on the 10th and 11th days of February, 1919, urge the Feed Control Ser- vice to maintain the present high standards which chemical analysis, and nutrition and feeding experiments, show to be just and fair for far- mer, miller, and ultimate feeder; we further urge upon the Legislature, our Governor, and others interested in the economic development of Texas, the importance of supporting the Feed Control Service in its ef- forts to maintain these standards, which are just and fair t0 every party at interest, and to the people as a whole.” FIGHTING THE BATTLE OF THE PEOPLE For ten years the Feed Control Service has been resisting the attempts‘ of certain cottonseed crushers to reduce the quality of cottonseed meal. They wish to add 17.5 per cent more hulls, and still sell the mixture to the people as cotton- seed meal. For a long time the Feed Control Service had no help from the people whom it protects. During this time the Feed Control Service had a disagreeable duty to perform, constant- ly resisting the attempts to lower the standards of cottonseed meal. Lately the Cattle Raisers’ Association, and the Sheep and Goat Raisers’ Association have given their assistance. It is now time that the people should know the facts, and assist in protecting themselves. The Feed Control Service made agreements with the Cot- tonseed Crushers’ Association, but hardly were the agree- ments written, before some of the cottonseed crushers would wish to tear up the agreements and lower the standards. It is time that this matter was permanently settled. When agreements are to be treated as “scraps of paper” more string- ent measures must be taken. There is only one way for this matter to be settled once for all, so that the Feed Control Ser- vice will be relieved from the constant pressure to permit cot- tonseed crushers to adulterate cottonseed meal with hulls, that is, for the legislature to adopt proper standards for cot- tonseed meal. PROPOSED LEGISLATION BY HALL A BILL S. B. 245 TO BE ENTITLED “An act _to amend Article 5903, Title 92, Revised Civil Statutes, 1911, empowering the Director of the Texas Agricultural Experiment Sta- tion to adopt standards or definitions for concentrated feeding stufis and such regulations as may be necessary for the enforcement of the law, pro- viding that such standards and definitions shall not be of a higher grade 22 TEXAS AGRICULTURAL EXPERIMENT STATION or standard than that adopted by the Feed Control Officials of the United States. “Be it enacted by the Legislature of the State of Texas: “Section 1. g That Article 5903, Title 92, Revised Civil Statutes, 1911, be so amended as to hereafter read as follows: “Article 5903-—The Director of the experiment station is hereby empowered to adopt standards or definitions for concentrated feeding stuffs and such regulations as may be necessary for the enforcement of the law. The said director shall have the power to refuse the registration of any feeding stuff under a name which would be misleading as to the materials of which it is made up, or which does not conform to the stan- dards and definitions aforesaid, provided that such standards and defini- tions so adopted shall not he of a higher standard or grade than that: adopted by the Feed Control Officials of the United States. Should any of said materials be registered and it is afterwards discovered that they are in violation of the provisions, the said director shall have the power to cancel the registration after ten days notice. The director of the Texas Experiment Station is hereby empowered to adopt such regulations as may be necessary for the enforcement o‘f all the provisions of this act. “The fact that the Director of the Texas Experiment Station has adopted a higher standard and definition for concentrated feeding stuffs than that adopted by the Feed Control Officials of the United States and higher than that adopted by other cotton raising states which prevents the cotton growers of Texas from successfully competing with the cotton growers of other states, creates an emergency and an imperative public necessity that the constitutional rule requiring bills to be read on three several days be suspended and that this act take effect from and after its passage and it is so enacted.” Introduced February 10, 1919. THE EFFECTS OF THIS BILL _ This bill is apparently innocent, but contains a “joker” which we have printed in bold face type. Some of the effects of this “joker” would be: 1. To largely transfer the authority to adopt definitions and standards for feeding stuffs from the Director of the Tex- as Agricultural Experiment Station to the Association of Feed Control Officials of the United States. 2. It would chiefly affect cottonseed meal, as the only standard adopted by the Feed Control Officials applies to this product. . , 3. It would reduce the protein content of cottonseed meal from 43 per cent to 36 per cent, thereby permitting the addition of 350 pounds more hulls per ton. 4. I_t would reduce Texas cottonseed meal from the high- est rank_1n the United States to the lowest; only South Caro- lina having such a low standard by law. COTTONSEED MEAL 23 5. It would permit the use of 714 pounds of hulls in Texas cottonseed meal as compared with 520 pounds as per- mitted by South Carolina. _ 6. _It might permit oat hulls to be sold in mixtures 1n this state as “Oat Feed.” 7. It might permit other adulterated feeds to masque- rade under the name of mixed feed. 8. It might cause disputes and litigation and interfere With the enforcement of the Texas feed law. WHAT THE LEGISLATURE SHOULD DO ‘Ne suggest that if any legislation is proposed, the follow- ing standards Which have been established in Texas by custom and usage and are based upon analytical determinations, nu- trition investigations and feeding experiments made during the past fourteen years, Would be fair and equitable to manu- facturers and consumers. . We believe that the cottonseed crushers should not be permitted to put one pound more hulls into cottonseed meal than has been done before. 1. No cottonseed product shall be sold, exposed or of- fered for sale Within the State of Texas under the name of choice cottonseed meal or cake which contains less than 48 per cent protein and 55 per cent protein and fat combined. 2. No cottonseed product shall be sold, exposed or of- fered for sale Within the State of Texas under the name of prime cottonseed meal or cake which contains less than 45 per cent protein and 51 per cent protein and fat combined. 3. No cottonseed product shall be sold, exposed or of- fered for sale Within the State of Texas under the name of ordinary cottonseed meal or cake which contains less than pgr cent protein and 49 per cent of protein and fat com- ine . 4. Cottonseed products containing 41.2 per cent crude protein shall be termed “Cottonseed Feed No. Four,” and the percentage of hulls present must be stated. 5. Cottonseed products containing 38.5 per cent crude protein shall be termed “Cottonseed Feed No. Five,” and the percentage of hulls present must be stated. 6. Cottonseed products containing 36 per cent crude protein shall be termed “Cottonseed Feed No. Six,” and the percentage of hulls present must be stated. 7. The product from pressing the Whole, clean, cotton- seed for the production of oil, should be termed “Whole-press- ed cottonseed.”