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THOMAS ASSOCIATES, INC.,
Cleveland, Ohio, September 15, 1966. Mr. FRANK R. HAMMILL, Jr., Counsel, Committee on Science and Astronautics, House of Representatives, Ray
burn House Office Building, Washington, D.C. DEAR MR. HAMMILL: Thank you for your September 12 letter and the copy of Chairman Miller's Bill H.R. 17424, which is a bill to promote and support representation of United States interests in voluntary international commercial standards activities, to establish a clearinghouse for commercial and procurement standards, and for other purposes.
I have reviewed the contents of this bill and am sympathetic with its intent but, frankly, seriously question the methods outlined to achieve the stated objectives. I have for many years been a very strong supporter of the American Standards Association, which is now the United States of America Standards Institute, as the sole agency responsible for standardization in the United States.
As I read the contents of the proposed bill, it would seem that its intent is to establish a separate organization to act as a clearinghouse in the area of domestic and international standardization, which I believe should be the primary function of the U.S.A. Standards Institute. I do agree that the performance of United States industry in the area of international standardization has, in the past, been woefully lacking for a number of reasons which we need not go into for the moment, other than to mention that one of the primary ones is cost.
It is my opinion that the objectives of the bill could be more effectively achieved by firm governmental support of the activities of the USA Standards Institute through grants, contracts, etc., rather than the establishment of a separate government agency to accomplish same.
In conclusion, it is my considered opinion that the USA Standards Institute, as it is now constituted, should be the agency which deserves the full support of government, industry, trade associations and technical societies.
Any movement to establish additional organizations in the area should be discouraged as being undesirable from the standpoint of diluting the effectiveness of this new organization. Thank you for giving me the opportunity of commenting on this bill. Yours very truly,
ALLEN P. WHERRY. P.S.—Unfortunately, I will be out of the country during the time of the public hearings and, therefore, will not be able to appear.
AMERICAN LUMBER STANDARDS ('OMMITTEE,
Washington, D.C., September 16, 1966. Mr. FRANK R. HAMMILL, Jr., Counsel, Committee on Science and Astronautics, House of Representatives,
Rayburn House Office Building, Washington, D.C. DEAR MR. HAMMILL: I have your letter of September 12, regarding H.R. 17424 introduced by Congressman Miller.
For the record, perhaps I should point out that the American Lumber Standards Committee, although its members are appointed by the Secretary of Commerce, is an autonomous organization operating under the auspices of the voluntary product standards program of the Department of Commerce. It is responsible for the maintenance and enforcement of the standard for American softwood lumber, currently SPR 16–53.
After reviewing the information submitted with your letter, it is my view that H.R. 17424 does not directly involve the functions of the ALS Committee.
The opportunity of commenting on this bill is appreciated. This is done with the understanding that such comments would not necessarily be interpreted as being the official position of the ALS Committee since this matter has not been considered by them.
The stated purpose of the bill appears to be admirable, and I have no obje tion to most sections of the bill as written. It should be understood that the activities of the ALS Committee has not involved any international trade excep possibly in connection with cooperation existing between this office and the office of the Canadian Lumber Standards Administrative Board. Any bill which might inject this Committee into any international activity would have to be viewed in a different light. As I interpret its provisions, H.R. 17424 would not force this organization into such activity.
Section 3 (a) and (b) of the bill appear unnecessarily to delegate the respaasibility of the Federal Government to certain non-government organizations deemed to be representative of the industry concerned. An undesirable prece dent might well be established in the adoption of these particular paragraphs as written. It is my view that the Federal Government should not be authorized to assign or delegate its responsibility in carrying out the purpose of the act
In summary, it is my opinion that the establishment of a central library by the Federal Government in making available information concerning existing standards as well as authorizing the Secretary of Commerce to promote and support United States participation in international standardization efforts would be considered worthwhile. This position is taken on the assumption that the adoption of the bill, as written, would not "open the door” to further government regulation in the field of standardization activities. Sincerely yours,
G. A. THOMPSON, Secretary.
AEROSPACE INDUSTRIES ASSOCIATION OF AMERICA, INC.,
Washington, D.O., September 19, 1966.
DEAR MR. HAMMILL: On behalf of the Aerospace Industries Association, I would like to express our appreciation of the Committee's interest in our comments and opinions on the policies set forth in H.R. 17424.
I have referred this bill and its explanation to the Association's Aerospace
KARL G. HARR, Jr.
Princeton, N.J., September 21, 1966.
DEAR MR. HAMMILL: Thank you for your letter inviting comments on H.R. 17424, a bill relating to voluntary international standardization activities as they affect United States industry.
In my opinion passage of this bill would aid materially in establishing a strong and healthy working relationship between industry and government in the area of national and international standardization. I fully support the objectives which the bill is designed to achieve. Sincerely yours,
GEORGE H. Browx.
ELECTRONIC INDUSTRIES ASSOCIATION,
Washington, D.C., September 22, 1966. Mr. FRANK R. HAMMILL, Jr., Counsel, Committee on Science and Astronautics, U.S. House of Representatives, Rayburn House Office Building, Washington, D.C.
DEAR MR. HAMMILL: In response to your letter of September 12, I am submitting the enclosed statement by the Electronic Industries Association on H.R. 17424 for incorporation in the published record of hearings on this legislation. Cordially,
JAMES D. SECREST,
Executive Vice President. STATEMENT OF DAVID R. HULL, DIRECTOR OF ENGINEERING OF THE ELECTRONIC
INDUSTRIES ASSOCIATION The Electronic Industries Association is a national trade association representing manufacturers of electronic parts, equipment, and systems for the entertainment, industrial and Government markets. It was organized in 1924 and, since that time, has provided the electronics industry with a wide variety of services including marketing data, industrial relations, Government procurement relations, legislative information, service technician training . . . and standardization--both national and international. It is by virtue of the Association's heavy involvement in this latter area that we feel qualified to take a position on H.R. 17424.
Since the issuance of its first standard, over thirty-five years ago, EIA has recognized the importance of standards to both the manufacturers and consumers of the products concerned. The Association, through its Engineering Department, conducts its standardization in over 200 committees staffed with approxi. mately 2500 industry engineers. These committees are comprised of representatives of both member and non-member companies and actively contribute to standardization in the following three areas:
(a) Industry Standards over 200 EIA standards and engineering publications are available covering a wide variety of products and techniques in the entertainment, industrial and military fields.
(0) National Standards—many BIA standards are submitted to the USA Standards Institute (formerly ASA) and have become National Standards.
(c) International Standards—EIA committees have prime responsibility for formulating the USA position in a large number of International Electrotechnical Commission (IEC) committees, and many members of these committees represent the U.S. as delegates in IEC meetings.
The degree of interest of EIA in international standards is exemplified by the fact that the Association has an International Standards Committee reporting directly to the Board of Directors and employs a staff engineer for international activities.
The Association's activities in international standardization of electronic products, parts and test methods is handled by participation in the International Electrotechnical Commission. EIA is represented by officers and council members on the U. S. National Committee of IEC.
The IEC has thirty-nine member nations. All but three are wholly Government financed, and the USA is the only participating country without some Government subsidy. The other nations provide highly competent technical representation at IEC meetings. Their interests, of course, are best served by having standards of their origin become international standards.
If we are to enhance our export trade, it is essential that we do everything possible to insure that our standards are adopted abroad. To do this, we must provide adequate representation and technical competence as well as continuity of delegates service in meetings of international standards bodies.
EIA provides secretarial service for USA electronic participation in IEC. Daring the past fiscal year more than 1500 documents, of which 1250 were of foreig origin, were disseminated and correlated in preparation for international meet ings, a very substantial and expensive operation.
USA delegates expenses are largely financed by our companies providing the services and covering the travel and subsistence of USA representatives. EIA finances the travel of certain technical experts from educational institutions. In combination, this represents a major contribution by industry.
Although we are sure that the report of the White House Conference on International Cooperation has been brought to the attention of the Committee one paragraph in the section on International Engineering Standards is so pertinent to EIA's position that we feel it worth quoting, as follows:
"We believe that in those cases where participation is less than adequate the principal factors appear to be (1) lack of understanding of the nature of international recommendations and of their present and potential impact on the economic welfare of the country, (2) present importance of international trade in a given item (for example, the ISO Committees on Photography and Cine matography, Computing Machines, and the IEC Committees on Electronics and some Electrical Apparatus get good support from American industry and are effective in the preparation of international recommendations, probably because of the recognized importance of international trade in these items. On the other hand, Committees dealing with rubber goods, pipe, case iron, and electrical instruments have received relatively little support.), (3) the number of re dundant standardization activities which in certain areas have caused confusion and unnecessary expense, (4) the cost of financing delegations, secre tariats, and chairmanships, and the lack of arrangements for sharing of such costs by those who woulă benefit from the activity. Competent delegations of two to twelve men are needed for each major technical committee meeting. Not only should these men be competent, but a high degree of continuity of service by particular individuals is essential in order that the American viewpoint may be presented from familiar sources, and so that the American delegation may maintain the respect and confidence of the delegates from other countries."
Although the electronics industry is supporting international standardization to a major extent, it is far short of the amount of effort necessary to represent effectively the U.S.A. in view of the extremely competent foreign delegates who benefit from continuity of personal involvement both at international meetings and in the preparation for such meetings. More often than not, U.S. delegates have to sandwich such tasks into a work day already overloaded with regular duties for their employers or spend their own time. To most U.S. companies in the electronics field it is a major sacrifice to allow their engineers time for these efforts. Because of the commercial significance of international standards, however, it is imperative U.S. delegates and participants be actively engaged in the day-to-day operations of industry. This is necessary, not only to prepare representative comments reflecting the U.S. position but to be able to immediately assess the commercial significance of any foreign proposals that might be spontaneously introduced at an international meeting.
As a means of making available experienced teams of such industry trained delegates, we feel that the passage of H.R. 17424 would make it possible for the Government to support in part engineers working in industry who would have a major responsibility for international standards. To provide an adequate body of trained experts might require the support of three engineers in each of the areas in which the U.S. is interested and wishes to participate. The importance of having the U.S. represented by industry trained engineers cannot be over-emphasized.
This concept of Government supported engineers in industry for this pur. pose can be thought of as a reciprocal of the Research Associate Program of the National Bureau of Standards. It is our opinion that with such an industrytrained/Government-supported team representing the U.S. on a consistent basis, the effectiveness of U.S. position will increase to the level envisioned as necessary by both the Government and industry. We feel that the proposed legislation could be utilized to accomplish this goal in the manner herein de scribed, and for these reasons the Electronic Industries Association supports the adoption of H.R. 17424.
AMERICAN IRON & STEEL INSTITUTE,
Washington, D.C., September 23, 1966. Mr. FRANK R. HAMMILL, Jr., Counsel, Committee on Science and Astronautics, House of Representatives, Rayburn Building, Washington, D.C.
DEAR MR. HAMMILL: Thank you for your letter of September 12, 1966, in which you invited steel industry testimony on H.R. 17424.
I would like to inform you that we have urged all members of he AISI Committee on Building Research and Technology and Building Codes and Regulatory Standards Subcommittee to take an active interest in this matter.
Because of the time factor, an AISI response to this matter is not feasible. Therefore, any interested companies will respond individually. I hope this letter can be included in your files on the subject. Sincerely,
John P. ROCHE, President.
INTERNATIONAL BUSINESS MACHINES CORP.,
Armonk, N.Y., September 23, 1966. Hon. J. EDWARD Roush, House of Representatives, Washington, D.C.
MY DEAR MR. Roush: I am writing this letter in connection with the Bill (HR 17424), introduced by Mr. Miller, August 30, 1966, and which has been the subject of public hearings by a special subcommittee under your chairmanship. We believe that this proposed legislation represents a significant step forward in furthering an effective international standardization program. The additional activities to be undertaken by the Department of Commerce will, in our view, contribute materially to the voluntary development of international standards.
In line with this overall purpose and in the interest of clarification, we would like to suggest for your consideration the following changes in the language of the Bill:
1. In the preamble, the use of the word "commercial" could be interpreted to exclude such standards as safety, terminology and definition, and methods of measurement. The intent, we assume, is to include these standards as well, and therefore, suggest that the word "commercial" be eliminated.
2. In Section 1, line 5, the phrase "standardization of products” appears. We do not believe that the intent is to encourage standardization of products as such, since this action could slow technological advance and impede innovation which is fundamental to a competitive, free enterprise system. We believe that the intent is the standardization of the characteristics of products, such as definitions, methods of test, performance, and interchangeability of components. We therefore recommend that the phrase be changed to read : “standardization of the characteristics of products.”.
In addition, we would like to offer the following comments which bear more on the implementation rather than the specific wording of the Bill :
Section 2A deals with United States participation in international standardization in cooperation with national and international standards bodies. We think it important that this participation be conducted primarly through the recognized standards bodies such as the newly reorganized United States of America Standards Institute (USASI) and the international bodies, International Organization for Standardization (ISO) and the International Electrotechnical Commission (IEC). We recognize, of course, that with respect to those international standards activities covered by treaties the lead must be taken by appropriate Government agencies, but even in this area we strongly recommend active industry participation.
Section 3C, line 10 relates to ... fixing of reasonable prices, fees, or charges ...." Many of the standards bodies rely on the sale of standards publications to finance a significant portion of their activities. It is our hope that the intent of these words is not to establish prices and fees for the standards documents, but, rather, to establish prices and fees for the services, which are not otherwise available, rendered by the proposed clearing house.