WITH A REPORT OF THE MEDICAL OFFICER OF HEALTH ON THE OBJECTIONS RAISED
BY THE BUTCHERS' TRADE SOCIETY TO THE BYE-LAWS PROPOSED FOR THE
REGULATION OF SLAUGHTER-HOUSES ***





  REPORT

  OF THE

  SANITARY COMMITTEE

  OF THE

  COMMISSIONERS OF SEWERS OF THE CITY OF LONDON,

  TOGETHER WITH A

  REPORT

  OF THE

  MEDICAL OFFICER OF HEALTH

  ON

  THE OBJECTIONS RAISED BY THE BUTCHERS’
  TRADE SOCIETY TO THE BYE-LAWS PROPOSED FOR
  THE REGULATION OF

  SLAUGHTER-HOUSES.

  LONDON:
  CHARLES SKIPPER & EAST, PRINTERS, ST. DUNSTAN’S HILL, E.C.

  1876.




 _At a Meeting of the Commissioners of Sewers of the City of London,
 held at the Guildhall, on Tuesday, the 4th day of July, 1876,_

 FREDERICK COX, ESQ., IN THE CHAIR.


A Report from the Sanitary Committee (WILLIAM CAVE FOWLER, Esq.,
Deputy, Deputy-Chairman), dated this day, was read--

On the Reference of the 23rd of May last, to consider the Letter
from the Local Government Board relative to the Slaughter-house
Bye-laws agreed to on the 14th of March last, and submitted to the
Local Government Board for confirmation, and on the objections of the
Butchers’ Trade Society to the said Bye-laws.

Submitting a Report from the Medical Officer of Health in reply to
the said objections, and recommending the Commissioners’ concurrence
therein.


RESOLVED--

That this Court doth agree with the Committee in their said Report, and
doth confirm and adopt the same.


ORDERED--

That a Copy of the Medical Officer’s Report be sent to the Local
Government Board in reply to their Communications therein referred to.


ORDERED--

That the Report be printed, and circulated as usual.

  HENRY BLAKE,
  _Principal Clerk_.




  REPORT
  OF THE
  SANITARY COMMITTEE.


We have, in accordance with your Reference to us of the 23rd May
last, considered the letter from the Local Government Board, dated
the 13th of May, relative to the new Bye-laws for the management
of Slaughter-houses within the City of London, agreed to by your
Honourable Court on the 14th of March last, and submitted to the Local
Government Board for confirmation. Also we have carefully considered
the letter of Messrs. Crouch and Spencer, with objections on behalf of
the Butchers’ Trade Society, to the said Bye-laws, enclosed in the said
letter from the Local Government Board for your observations.

We requested the Medical Officer of Health to give a detailed Report
in regard to the objections raised by the Butchers’ Trade Society to
the said Bye-laws, and we beg now to submit the same to your Honourable
Court.

We have carefully considered the said Report, with the Bye-laws, and
the said communications from the Local Government Board.

We have also received and considered a further communication from the
Local Government Board, with copy of a letter from Messrs. Crouch and
Spencer, enclosing further objections on behalf of the Butchers’ Trade
Society to the said Bye-laws, also a Report from a Dr. Whitmore, and
letters from certain residents of Aldgate in support of such objections.

We beg to recommend that your Honourable Court concur in the Report of
the Medical Officer of Health, and that a copy thereof be forwarded to
the Local Government Board in reply to their communication of the 13th
ulto.

The effect of this will be, to adhere to the several proposed Bye-laws,
except that as regards Bye-law No. 10, which is as follows:--

 “That the internal surface of the roofs and upper portions of the
 walls of the Slaughter-houses and Pounds, above the 7 ft. 6 in. of
 impermeable surface, be washed with quicklime at least once every
 month.”

It is suggested that it may be so far relaxed, that the monthly
limewhiting be required in the summer only, say from May to October,
and that in the winter months, say from November to April, the
limewhiting be required to be done once in three months.

And as regards Bye-law No. 18, which is as follows:--

 “That in case of any diseased or unsound cattle being brought to a
 Slaughter-house, Pound, or Lair, the occupier shall forthwith give
 information thereof to the Medical Officer of Health of the City of
 London.”

It is proposed not to insist upon the retention of the word “unsound,”
provided that the animals be slaughtered within a specified time of the
occurrence of any accident that may disable them.

All which we submit to the judgment of your Honourable Court.

Dated this 4th day of July, 1876.

  (Signed) FREDᴷ. COX.
  W. C. FOWLER.
  H. H. HEATH.
  W. I. LOWE.




  REPORT
  OF THE
  MEDICAL OFFICER OF HEALTH.


  _To the Sanitary Committee of the Honourable
  the Commissioners of Sewers._

  GENTLEMEN,

In compliance with your request that I should “give a detailed Report
in regard to the objections raised by the ‘Butchers’ Trade Society’
to the proposed ‘Bye-laws’” for the better conduct and regulation of
Slaughter-houses within the City of London, agreed to by the Honourable
the Court of Sewers, and submitted by them to the Local Government
Board for confirmation, and which “objections” were contained in a
letter forwarded to the said Board by the said Society, a copy of which
was sent to your Committee by the said Board for your consideration and
observations thereon, I beg to offer the following remarks:

There are 27 Slaughter-houses in the City of London, viz.: 24 in
Aldgate,[1] 1 in Bishopsgate, 1 in Farringdon, and 1 in Cripplegate
Ward: of these the following observations apply exclusively to Aldgate,
no “objections” to the Bye-laws having been expressed by the occupiers
of the remaining three.

The Bye-laws referred to were framed with a full knowledge of
the intended, and indeed threatened, opposition on the part of
the slaughterers and butchers of Aldgate, and every “objection”
mentioned in their letter to the Local Government Board was fully
and dispassionately discussed by your Committee during many lengthy
sittings, at each of which they invited, and were favoured by, the
presence of the Deputy of the Ward in which the Slaughter-houses are
situated.

This gentleman ably and forcibly supported the views propounded by the
butchers, and evinced the keenest anxiety to protect their interests.

Subsequently your recommendations respecting these Bye-laws were
adopted with surprising unanimity by the Honourable the Court of Sewers
without amendment or alteration; a number of Commissioners then being
present who are immediately interested in the butchering business, and
practically acquainted with its wants, concurring in their acceptance.

The initial difficulty in dealing with this question arises from the
anomalous conditions as to size, number, and areas, to be found in the
Slaughter-houses and adjoining premises at Aldgate.

The twenty-four Slaughter-houses in Aldgate are, with one or two
exceptions, situated side by side; all have a direct communication with
a shop facing High Street, Whitechapel, and six of them have no other
means for the entrance of cattle than by their being driven across the
footways and through the shop; a practice which renders the pavement
at times impassable, and causes terror and annoyance to the public.
These shops are for the most part low in ceiling height, and very
narrow in frontage, =one being but 9 ft. wide,--two 10 ft.,--one 10 ft.
6 in.,--two 11 ft.=,--and so on. In some of them the Slaughter-house
widens in the back part of the premises, but in several, viz., at Nos.
55, 58, 59, 60, 68, and 73, the whole business of a retail butcher and
slaughterer is conducted in the narrow strips above quoted.

Your Committee having viewed these places, will recollect that at No.
73, where the extreme width of the Shop and Slaughter-house was but 9
ft., there was no room to pass up and down the Slaughter-house when the
carcasses of the slaughtered animals were hanging, excepting by moving
sideways, and that the atmosphere of the place was pervaded by a hot,
moist, sickening vapour, for want of thorough ventilation; you must
also have remarked upon the general state of disrepair of the whole
of these Slaughter-houses, the dilapidated roofs, the blood-stained
and filthy state of the side walls, the uneven and broken condition
of the flooring, the imperfect, totally inadequate, and badly placed
water supply, the large accumulations of dung, offal, and blood, and
the defective and sluggish drainage, down the gratings of which you
could not fail to have seen a plentiful flow of crude liquid manure,
which the man in charge was industriously sweeping into the sewers,
to their great pollution; all these indicate a state of neglect which
could only have arisen from a consciousness on the part of the owners
and occupiers that the Legislature intended to abolish such places as
private Slaughter-houses upon the expiration of the Act of 1844, 7th
and 8th Vict., c. 84. Unfortunately, however, the so-called vested
interests of the butchers proved too strong with the Government for the
protection of the public, and Parliament in 1874, by the 37th and 38th
Vict., c. 67, was induced to perpetuate these Slaughter-houses in the
City of London, under such regulations it is your province to make and
maintain.

In order to be consistent, and to enable the Court of Sewers to
exercise a proper amount of control, each Slaughter-house must be
treated as a separate and independent building; and, in advising you as
to the best mode of securing such control, it has ever been a source
of deep anxiety and considerable embarrassment to me, how best to
reconcile the wants of modern sanitation, decency, and order, with the
inevitable sacrifices on the part of the occupiers of the smallest
of these places, which I foresee and confess to be demanded by the
institution of thorough disciplinary measures.

The necessity for treating each Slaughter-house as a distinct
structure “_per se_,” and the apparent consciousness of the inability
of the holders of the smaller ones to adapt themselves to efficient
regulations, is, I believe, the main cause of the opposition now made
to the Bye-laws, for I have reason to know that the occupiers of the
larger Slaughter-houses are ready to conform to the spirit of the
Bye-laws, albeit they are not in accord with us as to some of the
provisions therein.

Under the peculiar and exceptional circumstances of the case before
us, the question of dimensions so completely underlies the whole
contention, that I earnestly hope your Committee will call the
particular attention of the Local Government Board to the _size_ of
these small Slaughter-houses, as shown on the Plan made to scale by
your Engineer, and forwarded to the Board some time ago [a copy of
which, upon a reduced scale, is appended hereto]; for I can scarcely
imagine that the Board have the least idea of the diminutive space
in which slaughtering _on a large scale is going on night and day_ in
defiance of the principles of health or humanity.

The Board should also be informed that the slaughtering effected in
these places extends far beyond the requirements of the neighbourhood,
and that the plea of the Butchers that they provide marketable
commodities suitable to the necessities of the poor of their locality
is essentially unsound, from an economical point of view, it having
been found in places where Abattoirs obtain, that the poor readily
follow any market which offers them pecuniary advantages.

I now proceed to notice the various “objections” advanced in the letter
of the “Butchers’ Trade Society”:--They relate, for the most part, to
the _structural_ repairs rendered necessary by the present ruinous
condition of the Aldgate Slaughter-houses generally, which, in spite of
admitted neglect, due to their owners having expected their demolition
in 1874, when the Act of 1834 affecting Slaughter-houses expired, are
now resisted upon the score of expense.


FOOTNOTES:

[1] These Slaughter-houses are really in Portsoken Ward, but they are
always quoted as of Aldgate Ward, and will be so described in this
Report to avoid confusion.




REPLY TO “OBJECTIONS” OF THE “BUTCHERS’ TRADE SOCIETY” TO THE BYE-LAWS.


BYE-LAW I.

That each Slaughter-house be paved with asphalte, laid with proper
slopes and channels towards a trapped gully, and, where practicable,
such gully shall be outside the Slaughter-house and Pound.


OBJECTIONS.[2]

_The Butchers demur, firstly, to the use of asphalte, and, secondly, to
the gully being placed outside the Slaughter-house._


REPLY.

The reason for insisting upon _asphalte_ is to avoid _joints_, which
are inevitable in every other kind of pavement.

The joints in stone pavements, however well laid, cannot be made
durable, owing to the frequent concussions produced by the animals
falling heavily and suddenly when pole-axed, and the joints being once
cracked or broken readily admit through their interstices every kind of
liquid filth, which accumulates in the subsoil and decomposes there.

The flooring of the present Slaughter-houses in Aldgate is composed of
small, and badly laid, flag-stones, &c., which are loose, broken, and
uneven in many places, and which cannot be properly cleansed on account
of the inequalities of the surfaces.

The retention of this Bye-law will, of course, prevent the replacement
of the old flag-stones upon the reconstruction of the Slaughter-houses,
and involve the owners in some expense.

A smooth jointless pavement for Slaughter-houses was unanimously
considered the best at a meeting of the Royal Institute of British
Architects, in a discussion which followed the reading of a paper by
Mr. Darbyshire, on Public Abattoirs, 1st February, 1875.

The Metropolitan Board of Works is quoted by the “Butchers’ Trade
Society” as sanctioning the use of flag-stones, but this is scarcely
ingenuous, the truth being that the Board recommend _asphalte_ in
the _first instance_, but allow flag-stones set in cement as an
_alternative_.

The advantage of placing the gully _outside_ the Slaughter-houses, is
that it prevents the admission of solid matters into the drains, and
provided the floor be laid at a proper inclination towards the door,
all fluid materials can be readily conducted thence by gravitation into
the drain beyond, by means of sunken stone channels, or cast-iron boxes
having hinges, without the creation of unavoidable nuisance. These
channels should be provided at certain intervals with what are termed
“grids,” which prevent anything but liquids passing into the drain or
sewer.

“The _grids_ are hinged to fall back against the walls, and, on being
opened, reveal a cast-iron box or chamber, with a flange all round the
top edge, which rests on a rebate cast on the outer shell; this box
is movable, and is perforated through the bottom and sides; under
the movable box is another chamber opening direct into the trap,
which is cast to the outer shell of the frame work.”--(Darbyshire on
Abattoirs.)--These grids are in daily use at Manchester and elsewhere,
and are made by Bunnett and Co.

The scavengers should attend to the movable boxes at regular intervals,
and cart away all solid matter.

In the Edinburgh Abattoirs there are “two distinct sets of drains, one
for the surface water, which is conveyed directly into Lochrin burn,
the other for the soil, which is conveyed into large tanks, prepared
for its reception, and sold for agricultural purposes.” (_Encyclopædia
Britannica._)

It is impossible to over-estimate the importance of excluding blood,
offal or dung, &c., from the sewers at all times, but especially in
seasons of epidemic zymotic diseases, and it would be an inestimable
boon, and one by no means difficult of accomplishment, if the Scotch
system could be imitated at Aldgate.


BYE-LAW II.

That each Slaughter-house be drained by a glazed pipe drain, not less
than six inches in diameter, set in concrete and jointed in cement,
or otherwise made impermeable, and communicating directly with the
public sewer. That the gully at the inlet to the drain be trapped
with a stoneware syphon-trap, or other trap of approved material and
construction, and be covered with a grating, the bars of which shall
not be more than three-eighths of an inch apart; the grating to be
fastened with a lock and key, and kept at all times locked, unless
opened for cleansing or repair.


OBJECTION.

_That “it is very doubtful whether setting the drain pipes in
cement, whereby they cannot be got at, except by great breakage and
disturbance, is at all advantageous.”_


REPLY.

The advantages claimed for setting the drain pipes in, and upon cement,
are durability and strength; and if a pipe of six inches diameter be
used, there is but little liability of its becoming choked or requiring
repair for many years. Drain pipes laid on soft subsoil materials
frequently break asunder from the subsidence of such a matrix, or from
heavy weights falling suddenly upon them, from above, and our daily
sanitary work furnishes abundant evidence of the danger to health
arising from the fracture of drain pipes, where originally placed upon
improper ground, and especially when under such circumstances they are
subjected to violent blows.

In Edinburgh the Slaughter-houses are “laid with a thick well-dressed
pavement, resting on a stratum of concrete twelve inches thick.”


BYE-LAW IV.

That each Slaughter-house be provided with adequate cisternage and
water supply, or, where practicable, with a _constant_ supply of water,
and such arrangement of pipes as will enable the pavement and the walls
to the height of 7 feet 6 inches to be conveniently and quickly washed.


OBJECTION.

_The Butchers urge that_ four _feet is sufficiently high for the
washing of the walls._


REPLY.

The necessity for this alteration will be dealt with under remarks upon
Bye-law No. 6.


BYE-LAW V.

That each Slaughter-house be separated from any adjoining
Slaughter-house in a different occupation by a brick wall, of at least
nine inches in thickness, extending from the ground to the roof, so as
effectually to shut off all atmospheric communication between it and
the adjacent Slaughter-house.


OBJECTIONS.

_The Butchers object to the brick side walls between adjoining
Slaughter-houses being more than six or seven feet high, above which
they would have placed “the largest possible openings, fitted with
louvre boards.” They are of opinion “that the best construction in the
case of a row of Slaughter-houses would be, that there should exist
means of thorough ventilation from end to end and side to side.”_


REPLY.

This involves the most important change in the reconstruction of the
Slaughter-houses, and in order to explain my views fully upon the
matter, and avoid paraphrasing the same ideas, I must reiterate,
almost “_ipsissima verba_” the observations contained in my Report
upon the subject presented to you in June last, with such omissions or
alterations more recent information has enabled me to obtain.

I may, however, premise by stating that the present divisional
walls between the several Slaughter-houses are composed of wet,
partially rotten, and rugged, brickwork below, and rough, imperfect,
and defective, wooden partitions above, the whole of which are
supersaturated with organic animal matters, grease, and dirt.

The faulty construction of these Slaughter-houses was clearly brought
before the notice of the Select Committee of the House of Commons
in the evidence given by Sir J. Ogilvy and others, as recently as
1873, but the only action taken by Parliament to remedy the same in
the Slaughter-house Act of 1874 (which was based mainly upon the
recommendations of the said Committee) is comprised in Section 4,
which directs that “The Local Authority may from time to time _make_,
_alter_, and _repeal_ Bye-laws for regulating the conduct of any
business specified in this Act, which is for the time being lawfully
carried on within their jurisdiction, and the _structure of the
premises on which such business is being carried on_,” &c. And in order
to protect the trade from arbitrary action on the part of any local
authority, it is further enacted that “any Bye-law made in pursuance
of this section, and any alteration made therein, and any repeal of a
Bye-law, shall not be of any validity until it has been confirmed by
the Local Government Board.”

It is quite clear, therefore, that you are acting strictly within your
legal rights in calling upon the Butchers to put their houses in order.

Your visit to Aldgate must have convinced you that the premises of
these Slaughter-houses generally are too small for the enormous amount
of business done in them, and as, owing to the natural increment
of the population, this evil must ever be augmenting, it becomes a
serious question to determine whether a strong remonstrance should
not be addressed by the Commissioners of Sewers to Her Majesty’s
Government, or failing this to Parliament, against the continuance of
the smaller of these places, or by insisting that slaughtering should
only be carried on in houses of such dimensions as would ensure perfect
ventilation, and provide the means of carrying on the process with
efficiency. In order to perfect your powers, and establish a wholesome
check upon the slaughterers, a short Act might be obtained, giving the
Commissioners of Sewers authority to issue fresh licences, without
which no Slaughter-houses should be allowed to exist. The present
licences were issued in 1848, and have not been revised since that
time, whereas outside the City they are (as they ought to be) renewed
yearly.

_In the exercise of this important jurisdiction, the Metropolitan
Board of Works have actually abolished 284 Slaughter-houses during
the year 1875, having licensed 1,068 Slaughter-houses during the same
period._

Respecting the technical means to be adopted to remedy the admitted
defects of these Slaughter-houses, your Engineer will advise you; but,
without trenching upon the ground of that officer, it must, I think, be
patent that nothing short of an entire reconstruction of the side walls
and roofs of all of them will satisfy the requirements of scientific
sanitation, or ensure that complete _isolation_ of each house, which
is _the one essential requisite for carrying on the business of
slaughtering with due regard to the public health_. It is therefore a
_sine qua non_ that there should be a solid brick partition or side
wall between each Slaughter-house, and that the only opening allowed
therein should be for a door (where required), on the ground level,
and that this wall should extend from the floor to the highest point
of the roof. An exception to this may be made in those places in which
an open air passage of 4 or 5 ft. wide exists between the side walls
of two Slaughter-houses, for here it might be admissible to supplement
other means of ventilation and light by glazed sashes, which, however,
must be so made as to be readily closed, should, by any accidental
circumstance or oversight, a beast affected with any contagious disease
be found in the adjoining house.

Second only in importance to the closure of these side openings,
is the provision that the internal facing of all the walls in the
Slaughter-house should be of a non-absorbing nature, and I am still
of the opinion, which I ventured to urge unsuccessfully when the
Bye-laws were framed in November, 1874, viz., that the height mentioned
in Bye-law VI. is insufficient for the purpose, and that the _whole
wall-surface_ should be coated with a “hard, smooth, and impervious
material,” such as is now used in the wards of our best Metropolitan
hospitals. When this is done, the disgusting and blood-stained
appearance, seen on the walls of these Slaughter-houses on your recent
visit, will be impossible, and one fertile source of disease averted.

I entertain a strong objection to the partitions in any part of the
Slaughter-house, Pound, or Lair, being constructed of wood, for the
reason that this material becomes rapidly sodden by the constant
presence of hot moist air, in which state it must inevitably absorb
noxious and other vapours, and soon become saturated with albuminoid
organic matter, and afford a ready nidus for the development and
propagation of any disease germs which may be floating in the air.

The Butchers deny the existence of unpleasant odours in
Slaughter-houses; but whilst freely admitting this to be a matter in
which the senses of ordinary men may be differently affected to those
of persons constantly living in and enjoying an atmosphere, however
nauseous, I must insist that the air within a Slaughter-house can never
be wholesome so long as the disgusting practice of opening the paunches
of hot, reeking animals, directly after they are knocked down, is
allowed to continue.

From the nature of the food eaten by ruminants, and during its
disintegration and assimilation, enormous quantities of stinking
volatile gases are formed, and the sudden disengaging of these when the
intestines are ripped up and emptied, before being handed over to the
tripe-dresser, must always fill the surrounding air with what common
mortals would consider vile and poisonous smells.

You may remember I urged you to make a Bye-law prohibiting this custom,
and I regret the more it was overruled in Committee, since the only
excuse offered for its continuance was the very inadequate plea that
the guts of a large animal were too heavy and bulky to be removed
without being first deprived of their contents.

Mr. Simon, C.B., F.R.S., &c., &c., my talented predecessor, insisted in
the Blue Book before referred to, that “an atmosphere which smells of
organic decomposition, is an unwholesome atmosphere; that it at least
favours the spread, perhaps also what may virtually be considered the
production, of morbid infections.”

It has been urged that the closure of the present louvres and other
apertures in the side walls will restrict the necessary ventilation;
I am, however, of a contrary opinion, believing that it can be
demonstrated by the employment of an anemometer; _that in proportion
to the exclusion of disturbing currents of air from lateral sources,
will be an increase in the velocity by which the fresh incoming supply
will travel through the narrow passage from front to back of the
premises, and that a readier displacement of vitiated air will result_.
If this should prove insufficient, a constant upward direction of
ventilation can be accomplished by well-known mechanical contrivances
in the roof of each house.

Without reiterating the reasons which have led me to insist upon this
isolation of each Slaughter-house, I will only advert to the very
evident facility given for one Slaughter-house to infect its neighbour
should these side openings be allowed to continue, an objection which
would apply with fatal force should cattle suffering from contagious
disease be imported by carelessness or design into any one of them.

It being a well-ascertained fact that myriads of germs or
disease-spreading organisms may be given off in the cutaneous
exhalations, the excreta, and, possibly, the very breath of infected
animals, it is no exaggeration to affirm that one such beast might
decimate its neighbourhood, affecting alike the living cattle in the
Pounds and Lairs waiting for slaughter, and the dead meat hanging up to
cool in the Slaughter-house before it was carried away by the retail
butchers. In the latter case, the well-known power of warm fat in
rapidly absorbing all kinds of odours, good and bad, would render every
precaution to prevent the contamination of the meat already killed
inoperative.

It is no argument against these measures to urge that their necessity
has not yet been recognised by the unlearned, or to assert that no
practical difficulty has arisen in the direction just mentioned,
for it must be remembered that the great aim of all modern Sanitary
legislation is to discover disease in its germinal condition, and apply
such _preventive_ agents as will combat the extension of the mischief
when once discovered.

Interested persons have asserted that no injury to health has been
proved to result from the existence of Slaughter-houses, even in
densely populated and confined situations, but my own experience, and
that of every practical physician, leads to an opposite opinion; in
support of which I may recall the circumstance of my having recently
reported to you an outbreak of scarlet fever in the vicinity of
the Slaughter-houses in Aldgate, and again as lately as 14th March
last a case of typhoid fever in Somerset Street, at the back of the
Slaughter-houses, in a house in immediate connexion with the drains of
the Slaughter-houses and the “blood house” adjoining. Moreover, it is
a truism, established by recent researches in vital statistics, that
slaughterers and butchers should be regarded as an unhealthy class
of men, since they present a much higher rate of mortality than is
observed in other trades.

It is now established as an actuarial fact,[3] that this
unhealthfulness of calling applies to all trades in connection with
animal food, and this has been supposed to depend, in the case of
butchers and slaughterers,--_Firstly_, from their constantly inhaling
an atmosphere impregnated with animal matter;--_Secondly_, from their
exposure to sudden alternations of temperature and the vicissitudes of
weather; and,--_Thirdly_, from the large amount of animal food they are
known to eat. It has also been stated with much force that they are
necessarily exposed, more than other persons, to fevers and zymotic
diseases, from their constantly breathing an atmosphere charged with
decomposing, and often putrescent, animal matter.

Respecting the separation of the Pounds from the Slaughter-houses,
I still retain a strong conviction that such is both necessary and
expedient, although I am not insensible of the difficulty of carrying
it out in some few of the Slaughter-houses, whose cramped dimensions
render this and other requisite accommodation well nigh impracticable.
In these cases the owners should be compensated, and the places closed.

Before a clear idea can be entertained of the possible and impossible
improvements in these Slaughter-houses, I strongly recommend that a
ground plan[4] be prepared of the whole block in High Street, showing
to scale the exact size of each Shop, Lair, Slaughter-house, and
out-building, with so much of the surrounding property as will provide
a back way into the Slaughter-houses upon a give-and-take line as
between immediate neighbours; should the owners find it their interest
to combine for such purpose.

By means of this plan it may be seen how far it may be practicable
to reconstruct the whole of these places upon one agreed basis, and
prevent, _inter alia_, the objectionable practice of driving the
cattle across the public footways into the Slaughter-houses, so much
complained of.


BYE-LAW VI.

That the inner surface of the walls of every Slaughter-house be covered
with slate, stone, or other hard, smooth, impervious material, to the
height of 7 feet 6 inches, and that above this height to the roof the
walls be cemented.


OBJECTION.

_The Butchers say, “It is a useless expense to extend the smooth,
impervious material beyond four feet,” and that “there is no practical
advantage in cementing the whole of the upper part of the walls of
the Slaughter-house; on the contrary, the hard bricks are superior to
cement, which will break off.”_


REPLY.

The height of the “dado” was increased from 4 feet 6 inches to 7 feet 6
inches, in consequence of my having inspected a Slaughter-house outside
the City, and finding 4 feet 6 inches insufficient to protect the walls
above from the splashing of blood and filth, the “dado” itself being
clean.

In Edinburgh the walls are formed of solid ashler stone to a height of
_seven feet_.

The advantage of covering the inner surfaces of the Slaughter-house
walls with an impervious cement are twofold: _Firstly_, the walls can
be much more easily washed and kept clean. _Secondly_, it obviates the
liability of the walls becoming saturated with decaying nitrogenous
matter by the constant absorption of moist animal vapours by porous
bricks. [This precaution was suggested by a perusal of an account of
the practical experiments of Professor Pettenkofer, of Munich, who has
clearly demonstrated in various ways the extreme porosity of ordinary
brick walls.] _Lastly_, a hard, smooth wall prevents the ingress and
lodgment of vermin. The question of expense raised by the Butchers is
hardly worthy of prosperous and wealthy tradesmen, and the objection
that the cement would “break off” is too frivolous to answer.


BYE-LAW VII.

That each Slaughter-house be provided with adequate lairage or
poundage, separated from the slaughtering space by a closed partition,
extending from the floor to the roof, formed of brick, stone, slate,
or other similar material, having a smooth impervious surface, to a
height of at least 7 feet 6 inches from the floor. That in all cases
where from the present plan of the premises a door is needed between
the Lair or Pound and the slaughtering space, such door be provided
with spring hinges, and be kept closed when not open for the passage
of cattle, but that where other means exist of taking cattle from the
Lair or Pound into the Slaughter-house, without passing through shops,
or over important public ways, no door shall exist between the Lair or
Pound and the Slaughter-house.


OBJECTIONS.

_The contention here is that the separation of the Slaughter-houses
from the Pound will impede ventilation, and that a partition six feet
high is sufficient for the purpose, the Butchers denying that any
“offensive effluvia arise from a live animal.” It is assumed that the
reason for this Bye-law is based primarily upon the idea that the
animals are distressed by seeing the process of slaughtering whilst
waiting their turn for the pole-axe. It is further objected that the
spring hinges are likely to lead to accidents to men and beasts._


REPLY.

The chief considerations in support of this Bye-law are given in the
extract of my Report on 1st June, 1875, above quoted. I may, however,
say, in addition, that the possibility of the animals waiting for
slaughter seeing the process of killing other animals, formed no part
of the argument.

Again, the Butchers’ objection on the score of ventilation is based
upon the supposition that the Pound must necessarily be of the
same height as the Slaughter-house, which does not follow, as the
accompanying Diagram will show:--

[Illustration]

The spring hinges ordered in this Bye-law will ensure the door between
the Slaughter-house and Pound being kept closed, but the Butchers may,
if they prefer it, hang the doors by balance weights, so as to slide
up and down like an ordinary sash window, by which means the direful
consequences predicted as likely to result from the use of spring
hinges may be avoided.


BYE-LAW VIII.

That where any Slaughter-house or Pound cannot be sufficiently
ventilated by openings on to the public ways, or on to other open
places, it shall be ventilated from the roof, which shall be so
constructed as to admit freely of the escape of air, and that rings for
burning gas be fixed in the roof so as to increase the upward current
when a-light, and that both Slaughter-house and Pound be properly
lighted either from the public ways or other open spaces, and where
that be not practicable, then from the roof.


OBJECTIONS.

_The chief arguments relate to matters quite irrelevant, and are very
confused and unintelligible. The only part of the “objection” belonging
to this Bye-law is that which refers to the proposal for increasing
the efficiency of the ventilation by rings of gas, which the Butchers
characterise as “absurd.”_


REPLY.

The question raised here is as to the proper mode of ventilation and
lighting, and seeing that it would be worse than folly to perpetuate
the evil of allowing an intercommunication between the side walls of
some of the present ill-devised, and worse-kept, Slaughter-houses in
Aldgate High Street, your Committee were driven to the alternative of
requiring both light and ventilation to be sought for in the roof.

The ring of gas spoken of so contemptuously by the Butchers will have
the effect of rarefying the vitiated air in the Slaughter-houses during
the process of slaughtering, and by producing an up-current, quicken
the ventilation.

Upon this point Mr. Darbyshire, before quoted, says, speaking of
his work at Manchester, “the Slaughter-houses are well lighted from
the roofs, top lights being superior to side lights for purposes of
slaughtering.” All the Markets recently constructed by the Corporation
of London are similarly lighted and ventilated, and at the Abattoir
in Edinburgh the whole of the ventilation is carried on by large
ventilators, and other contrivances, in the roof.


BYE-LAW IX.

That each Slaughter-house and Pound be thoroughly washed over the
entire surface of the walls to the height of 7 feet 6 inches, and
over the whole surface of the floor directly after slaughtering is
completed, or at least once in every twenty-four hours.


OBJECTIONS.

_The substance of the objections raised is that the requirements
for washing are too stringent, with a reiteration of the grievance
of a dado 7 feet 6 inches; also the Butchers find it “difficult to
imagine why the walls and floor of the Pound, as well as those of the
Slaughter-houses, are to be washed after slaughtering,” and seem to
imagine that the washing is required every twenty-four hours, including
Sundays, whether slaughtering is going on or not._


REPLY.

The provision for thoroughly cleansing, once in each twenty-four
hours, Slaughter-houses and Pounds that are in constant use, is too
obviously necessary to require any defence, and the quibble raised by
the Butchers about Sunday cleaning is, I presume, intended as a joke.


BYE-LAW X.

That the internal surface of the roofs and upper portions of the
wall of the Slaughter-houses and Pounds above the 7 feet 6 inches of
impermeable surface be washed with quicklime at least once every month.


OBJECTIONS.

_That the requirements for the limewhiting are excessive, and that, if
insisted upon, would be “oppressive and useless.”_


REPLY.

I am of opinion that this Bye-law may be relaxed, and that it will
suffice if the _monthly_ limewhiting be required in the _summer_ only,
say from May to October; and once in _three_ months in the colder
seasons, say November to April. The necessity for this periodical
cleansing with lime would be made abundantly clear if the Local
Government Board would send one of their own Medical Inspectors to
see the places as now existing; who would be astonished, as your
Committee were, to observe the foul, black, sooty, and greasy state of
all that is left of the ruins of the timbers originally forming the
roofs of some of the Slaughter-houses in Aldgate, and perhaps concur
in remarks freely expressed by outsiders, that no regulations can be
too stringent for the management of a business, which under the most
careful supervision and with every intelligent precaution, is repulsive
and offensive to the senses.

Assuming that the observance of the proposed Bye-laws will unavoidably
compel a partial reconstruction of the Slaughter-houses in Aldgate,
and substantial repairs in the adjacent structures, the washing
with quicklime was ordered with a view of providing a suitable and
inexpensive coating for the new wood-work of the roofs, &c., for, owing
to the constant presence of Sulphuretted Hydrogen in Slaughter-houses,
paint is inadmissible from the circumstance that it would speedily
be turned black by the action of such gas upon any mineral pigment
employed. The limewhiting if used _hot_ would act as a powerful
disinfectant and deodoriser, as well as having the effect of greatly
reflecting the light in the Slaughter-house, and giving the place a
cool and clean appearance.

The Metropolitan Board of Works in their 6th Bye-law require that “the
occupier shall keep the inner walls of every Slaughter-house always
_thoroughly clean_ and in _good order and repair_, and shall cause the
internal surface of the _roof_ and _upper portions of the walls_ to
be thoroughly washed with quicklime _at least_ once in _every three
months_.”

The Butchers have probably overlooked this Bye-law in quoting the
action of the Metropolitan Board of Works.


BYE-LAW XV.

That no Slaughter-house or Pound be used for any purpose other than
that for which it is licensed, and that no slaughtering be conducted
within public view.


OBJECTION.

_The Butchers maintain that the Pound is not included in the Licence
for the Slaughter-house._


REPLY.

It is quite true that the word _Pound_ is not used in the Licence for a
Slaughter-house, but the Act of Parliament, 1874, distinctly provides
that the Bye-laws shall extend to the “_premises_” generally.


BYE-LAW XVIII.

That in case of any diseased or unsound cattle being brought to a
Slaughter-house, Pound, or Lair, the occupier shall forthwith give
information thereof to the Medical Officer of Health of the City of
London.


OBJECTION.

_That the retention of the word unsound might involve the Butchers in a
charge of Slaughtering Diseased Meat._


REPLY.

I should not insist upon the retention of the word “_unsound_” if some
guarantee could be exacted that the animal would be slaughtered within
a specified time of the occurrence of any accident which might disable
it; although it must be remembered that the flesh of a beast suffering
pain, or deprived of the full use of all its functions, rapidly
deteriorates in quality and nutrient properties.


BYE-LAW XXI.

That every person occupying a Slaughter-house shall cause the works
needful for complying with these Bye-laws to be forthwith executed,
and when completed shall not permit any alteration to be made in them
without the sanction of the Commissioners of Sewers of the City of
London, and that the whole of the works and regulations be carried out
to the approval of the Medical Officer of Health.


OBJECTION.

_That the Medical Officer of Health should not be the judge of the mode
in which the works ordered by the Bye-laws are executed._


REPLY.

This Bye-law provides a salutary check upon the active resistance the
Butchers seem ever ready to offer to rules intended for their own
benefit, no less than the protection of the public health, and the
general arrangements and discipline of a Slaughter-house belonging
exclusively to the Sanitary Department, your Committee thought it would
save circumlocution if the Medical Officer of Health was made amenable
to the Court of Sewers for the due maintenance of the Bye-laws in their
integrity.

So far, however, as I am concerned I shall be very thankful to be
relieved from the odious duty of enforcing regulations which are so
ungraciously acquiesced in by the persons on whose behoof they are
made, at the same time I shall never shrink from accepting whatever
responsibility may be connected with my office.

It is quite untrue, as stated by the Butchers’ Trade Society, “that
the Bye-laws in question have been framed by persons totally without
practical acquaintance with the trade,” the fact being, that they were
prepared with the active assistance of several Members of the Committee
of great experience as providitors, two of whom are large carcass
butchers, and two others are extensively connected, commercially and
officially, with the butchering interests, and well informed upon the
economy of Markets and Slaughter-houses. Again, the Committee was
attended at each of its sittings by the Deputy of the Ward in which
the Slaughter-houses are situated, who was specially invited to attend
upon each occasion, and who generously and frankly avowed himself the
advocate of the slaughterers. This gentleman took part in all the
discussions, and argued forcibly and fully every point in connexion
with the subject; but beyond this, your Committee’s Report was further
analysed and criticised by the General Court of Sewers, amongst whom
were many Commissioners practically and intimately acquainted with
the whole bearings and requirement of the question. As you are aware,
the Court adopted your Report, without amendment or alteration, being
satisfied of the wisdom and expediency of the Bye-laws compiled by you.

The remarks of the “Butchers’ Trade Society” relative to the Report
being passed by the Court of Sewers with “closed doors” require one
word of explanation: The exclusion of strangers at the time the Report
was presented was not dictated by any desire to conceal the purport of
its contents, and indeed had nothing to do with the main question of
its adoption, but was resolved simply in order that the Solicitor might
read a confidential communication having reference only to a technical
legal proposition as to the mode of enforcing the said Bye-laws should
they be sanctioned by the Local Government Board.

In conclusion, I will only add that, having given my best attention to
the whole subject, and carefully considered the not very formidable
“objections” raised by the butchers, I have arrived at the honest
conviction that no substantial grounds are therein advanced which
would justify you, as the Sanitary Authority in the City of London, in
varying the requirements of the Bye-laws submitted for approval to the
Local Government Board, beyond the concessions herein described.

Adverting to my individual action in the matter, I may here repeat that
I am quite unconscious of the smallest desire to limit the usefulness
or cripple the operations of an important and valuable trade, and that
I have endeavoured to reconcile the desires of the occupiers of the
Slaughter-houses with the imperative requirements of the public health;
nevertheless, I cannot help sharing the conviction of all competent
Sanitarians, that the perpetuation of densely packed Slaughter-houses
in the midst of a close population, where the introduction of a
sufficient supply of light, air, and ventilation, is physically
impossible, was a lamentable error of legislation, which every
unprejudiced observer admits will, and _must_, be remedied, whenever
the exigencies of public health are allowed to outweigh the antagonism
of interested and uncompromising opposition.

I feel it necessary to say as much as this, since I have been credited
with more than my share in the preparation of the materials upon
which you have deemed it wise and expedient to frame these Bye-laws,
an impression which has involved me in no small amount of abuse and
obloquy.

  I have the honour to be,
  GENTLEMEN,
  Your obedient Servant,

  WM. SEDGWICK SAUNDERS, M.D.,
  _Medical Officer of Health_.

  GUILDHALL,
  _27th June, 1876_.


FOOTNOTES:

[2] The “objections” are quoted in abstract only, in order to save
space, but the sense of the same has been scrupulously observed.

[3] In a paper on the “Influence of Occupation upon Health,” read by
Mr. F. G. P. Neilson, F.S.S., before the Institute of Actuaries, and
published in their Journal, July, 1872, it is shewn that in the forty
years of age, 25 to 65, the mortality of butchers is 17·9 per thousand
living, and that of poulterers 21·0, as against 10·6 of gardeners,
12·4 carpenters, 13·4 shoemakers, 16·8 stonemasons, &c. The results
were obtained by a comparison of the whole of the mortality of England
and Wales, 1860-1, with 1,147,243 years of life of members of Friendly
Societies.

[4] This has since been done, and a copy sent to the Local Government
Board.




POSTSCRIPT.


Since the foregoing was written I have received copies of additional
documents forwarded by the “Butchers’ Trade Society” to the Local
Government Board, and, in accordance with your request, have perused
and considered the same.

These communications begin with a long letter from the above named
Society, consisting of extracts from my Report on Slaughter-houses,
dated 1st June, 1875, with observations upon the same, given point by
point in parallel columns.

These remarks are really little more than a “_réchauffé_” of those
already set forth in the voluminous epistle of the Society, dated 10th
April, 1876, addressed to the Local Government Board, and I fail to
recognise any more important differences than the following, viz., some
very ungracious and totally irrelevant reflections upon the conduct
of the District Sanitary Inspectors, for the forbearance shown by
those officers in allowing the greatest latitude as to the defects and
nuisances observed in the butchers’ premises to continue with as little
interference as possible until the new _régime_ could be established;
also a statement that your Engineer is at variance with myself in the
recommendations given to your Committee, the truth being that they were
prepared by that officer in conjunction with your Solicitor and myself.
Further, the Society inform the Local Government Board, that disease
germs have never been known to rise to a height of six feet, and that
therefore the side walls separating adjoining Slaughter-houses need not
be built as high as the Bye-laws require! This is a fair sample of the
recklessness with which the “Butchers’ Trade Society’s” last production
has been framed, and pays a poor compliment to the discrimination
of the Local Government Board, who may, if they think fit, educate
the Society to the fact that disease germs have been known to travel
many thousands of miles, carrying with them cholera and kindred
diseases from the far East to the distant West;--a corresponding
degree of ignorance characterises the dicta of the butchers upon
the physical laws which govern the movements of currents of air,
and which for convenience is called ventilation. Again, the Society
claim an exceptional state of salubrity and freedom from disease for
butchers as a class--a proposition which I have already shown you is
untenable. Further information may be obtained upon this subject from
a Report written by Dr. Buchanan, one of the Medical Inspectors of
the Local Government Board, upon the connection between scarlet fever
and cow sheds, in a district under his charge. Lastly, the Society
ask, whether in my judgment the butchers would be less unhealthy in
the Slaughter-houses as arranged according to my plan, and I answer
broadly and unhesitatingly, Yes.

The remaining letters comprise one from the Reverend the Vicar of
St. Botolph, whose testimony as to the general condition of the
Slaughter-houses is opposed to the evidence of your own senses when
visiting the places, and is otherwise grossly inaccurate; also
letters from two resident medical practitioners certifying as to
the healthiness of the neighbourhood of Aldgate in general, and
the Slaughter-houses in particular--also a detailed Report from a
Metropolitan Medical Officer of Health, who has so implicitly adopted
every “objection” made by the butchers to your Bye-laws, that I am
irresistibly forced to the conclusion that he is either the author of
such “objections,” or has lent a too credent ear to the gentleman he
mentions as having accompanied him in his survey, and “who gave him
much valuable information, statistical and otherwise.” Upon fairly
balancing the whole matter, I cannot see any reason to modify the
opinions expressed in my Report of 27th June last, and in apportioning
the value to be awarded to the conflicting testimony offered to you,
I must ask you to remember that the strenuous efforts in the way of
resistance made by the butchers, and my own justification of the
principles of right and propriety, which have alone dictated my advice,
rest upon totally distinct bases.

  W. S. S.

  GUILDHALL,
  _14th July, 1876_.


CHARLES SKIPPER AND EAST, PRINTERS, ST. DUNSTAN’S HILL, E.C.


PLAN OF SLAUGHTER-HOUSES IN THE CITY OF LONDON.


NOTE

 _The_ Light Red Tint, _shews buildings principally constructed of
 Brick_.

 _The_ Red Tint, _shews Buildings constructed of Brick, and Inhabited_.

 _The_ Yellow Tint, _shews buildings principally constructed of Wood_.

  _William Haywood_
  _July 1876_




Transcriber’s Notes

In a few cases, minor errors in punctuation have been fixed.