the public resides in its ability to serve as a means for interchange of technical information. Hence, we have not felt that it is within our province to give opinions upon prospective legislation. Should this proposed bill be enacted into law, please be assured that the Society of Automotive Engineers would be most happy to contribute toward the objectives of the bill within the limits of its capabilities and competence. Thanks for having thought of us in connection with this proposal. Sincerely, JOSEPH GILBERT, Secretary. THE SOCIETY OF THE PLASTIC INDUSTRY, INC., Hon. J. EDWARD ROUSH, DEAR CONGRESSMAN ROUSH: We appreciated receiving a letter from Frank R. Hammill, Jr., Counsel to your Committee, inviting The Society of the Plastics Industry to comment on H.R. 17424. Let me say at the outset that we are in favor of the thrust of the legislation, but we also endorse wholeheartedly the suggestions made during your hearings by Mr. John D. Ritchie of the American Plywood Association. Specifically, we endorse Mr. Ritchie's recommendations that (1) the legislation leave no question but that the Office of Commodity Standards will be preserved to perform its present functions, and (2) that any clearing house activities will be conducted by a public agency with full control of its day-to-day activities. By way of informing you more fully about our interest in this matter, please be advised that The Society of the Plastics Industry, Inc., through its more than fifty functional Divisions and Committees, represents a broad spectrum of manufacturers of plastics raw materials, end products, and machinery for the manufacture of plastics goods. The company members of the Society are believed to be responsible for more than 85% of the dollar sales volume of plastics in the United States. These same companies obviously have a very vital interest in overseas sales and the development of overseas markets. For a great many years, the Society has utilized the facilities of the Office of Commodity Standards of the Department of Commerce for the development and promulgation of domestic Commercial Standards. More than thirty such standards have already been promulgated by the Department of Commerce and work on many more is pending. Indeed, it is our understanding that the Office of Commodity Standards has promulgated more useful Commercial Standards for the plastics industry, than for any other basic segment of our economy. This, of course, bespeaks the great satisfaction we have always had for the fine work of the Office under the procedures it employs to assure fair and objective Standards development. It is well known that the Society has, at every opportunity, urged the retention and improvement of the Office of Commodity Standards because we believe it has served industry well. As Mr. Ritchie has pointed out in his statement, the Office has been preserved and its activities up-graded substantially very recently despite unfortunate moves which have been made or threatened on occasion to abolish it. We have opposed, and will continue to oppose any such moves because we believe the Office of Commodity Standards has a unique capability, as a government body, for objective evaluation and promulgation of Commercial Standards designed to serve the best interests of industry and the public. In considering the proposed legislation, we have carefully reviewed the statements made by all of the parties, including the representatives of the Department of Commerce. Our consideration of these statements and the legislation in its present form convinces us that a great deal of good can be accomplished by its enactment, provided that the broad enabling clauses in the Bill are not used in any way to undermine or detract from the standards working facilities available through the Department of Commerce at the present time. We agree wholeheartedly with the basic aim of the legislation, i.e., to bring about improvements in our international trade position by making available funds which will allow for expanded and more effective United States participation in international standards work. Indeed, we should point out here that the Society has continually sought to advance the interests of its membership in international standards, as it is best demonstrated by the fact that we have fully supported the International Standards Organization Technical Committee 61 of the American Standards Association (now the United States of America Standards Association) efforts in this area through substantial contributions of the Society's funds. Additional contributions have been made in the way of the time of plastics industry expert personnel who have attended a great many meetings of such bodies as the International Standards Organization. A representative of this organization has for years served as Secretary of ISO/TC 61 having attended meetings of the Committee wherever held at the Society's expense. While thus supporting the primary legislative purpose here, we also agree wholeheartedly with Mr. Ritchie and the American Plywood Association as to their suggestion that your Sub-Committee should include in the legislation a "provision to the effect that the legislation shall in no way be construed as impairing or affecting the authority of the Department of Commerce to promulgate voluntary standards, both domestic and international, under the Department's own procedure." Mr. Ritchie's explanation of the rationale for such a limiting clause comports entirely with our own views. Likewise, we agree completely with Mr. Ritchie's suggestion that the proposed clearing house service for the collection and dissemination of engineering, product, and governmental procurement standards be operated and maintained by a public agency instead of a private organization. In this connection, it would appear pertinent to mention that the Department of Commerce has already established a "Clearing House for Federal Scientific and Technical Information" so it would seem that this entity could be readily expanded, or in some way adapted, to provide the clearing house service that would be called for by the legislation before you. We do hope that this letter will be of value to you in connection with the subject legislation and we thank you in advance for your consideration of our position. Sincerely yours, WM. T. CRUSE, Executive Vice President. INTERNATIONAL ASSOCIATION OF ICE CREAM MANUFACTURERS, Mr. FRANK R. HAMMILL, Jr., Counsel, Committee on Science and Astronautics, House of Representatives, Rayburn House Office Building, DEAR MR. HAMMILL: We appreciate your invitation of September 12 inviting our comments on H.R. 17424. The International Association of Ice Cream Manufacturers is comprised of members producing 85% of the frozen desserts in the United States, 75% of the volume in Canada and additionally has members in eighteen other countries. Our membership in the United States is located in every state of the union. For many years we have had vital interest in the engineering and commodity standard activities of the Department of Commerce. Our first experience with this activity dates back to 1932 when a Simplified Practice Recommendation for "Ice Cream Cups, Cup Caps" was promulgated. Since that time many other frozen dessert containers have also been standardized, benefiting both the public interest and the ice cream industry. We wish to endorse the statement made by Mr. J. D. Ritchie. Regional Vice President of the American Plywood Association, who appeared before a special subcommittee of the Committee on Science and Astronautics. While in principle we support the fundamental objectives of H.R. 17424, we like Mr. Ritchie and other directly affected industries, have great concern with certain portions of the bill. Our paramount worry is that such proposed legislation could be interpreted to mean the curtailment or the eventual abolishment of the Office of Commodity Standards of the National Bureau of Standards. The domestic standardization program of this office over the years has provided an essential and important role in fostering packaging criteria for the manufacturing, distributing and buying practices for frozen desserts. To decrease in any way the availability of this vital function of the Department of Commerce would be a backward step. To the industries of the United States, the Government activity of coordinating, reviewing technically, and issuing industry proposed standards provides a superb example of the beneficial role which Government can play in the supervision and promotion of a free enterprise economy. In this connection, it is significant that Government participation here has not been thrust on the industries concerned, but that on the contrary each industry has sought it on its own initiative as a vital service to its operations. While private standard writing organizations also do valuable work in the cause of standardization, we believe that the Government is particularly well fitted for the many-faceted role of clearing house, impartial arbiter, technician, and protector of both industry and consumer, which is essential to the effective performance of this activity. The National Bureau of Standards is developing a knowledge of industrial technology which makes it highly competent in the intelligent development of commercial and other engineering standards. In giving full and fair consideration to the needs of both the trade and the consuming public, the Bureau has ready access to various other Government agencies which lend their expertise to the solution of the many problems raised in standardization. Technical details and tests are considered by appropriate divisions of the National Bureau of Standards and other technical assistance is enlisted as needed. Other agencies, which we understand, receive appropriate Government commodity standards for review, include the Federal Trade Commission, the Department of Justice, the General Services Administration, the Department of Agriculture, the Department of Defense, and various offices concerned with domestic and foreign trade, small business, transportation, labor, etc. As specific questions arise relating to their fields of responsibility, these agencies respond promptly with information and recommendations. It may be noted, in this connection, that this Government program with its built-in safeguards has been able to alleviate what one trade association has termed "the specter of antitrust prosecution for work as constructive as standardization." Industry trade organizations and their members are well aware that efforts to establish engineering and commodity standards can raise and have raised-serious problems under the Federal antitrust laws. These associations and firms, in seeking to comply in good faith with the spirit and letter of the antitrust laws, also know that the Federal Government's participation in the issuance of voluntary engineering and commodity standards is an important practical safeguard for both the public and the industries themselves. It is very doubtful that trade associations would engage in standardized and simplified practice activities of the Office of Commodity Standards was to be abolished. They simply would not risk the legal exposure, no matter how desirable standardization is to industry, to consumers and to the Government. Despite an unqualified success, the program has, from time to time, been subjected to efforts of private organizations to take over the commodity standards functions of the Department of Commerce. These efforts have in each case been made against the wishes of the industries who actually use the Government service, and they have in each instance been successfully resisted by the industries who rely on the service. The Secretaries of Commerce and the Congress have repeatedly protected the program against these attacks. For example, Secretary Henry Wallace in 1945 declared pointedly, "I do not believe... that the Department of Commerce can properly close the door to industry and other economic groups which request the direct assistance of the Department in developing and in publishing voluntary standards on their behalf." Then, in 1951, following an administrative transfer of the activity and a sharp cut in its funds, the Senate Appropriations Committee came to the relief of industry by inserting a sentence in the appropriations bill directing that, "this important (commodity standards) work be kept at its current level. The Commodity Standards Division performs work which is very valuable to private business." Very recently, a body of the Congress has once again emphasized the importance to industry of this Government function. In its report following hearings on "The Impact Upon Small Business of U.S. Softwood Lumber Standards," the Subcommittee of the House Select Committee on Small Business headed by Rep. Roosevelt noted that, “. . . it is clear that the commodity standards program as presently administered by the Department of Commerce continue to play an active role in the field of commodity standards." We therefore urge that if the Congress passes this bill or another version of this kind of legislation that it signify its intent to preserve and strengthen the Office of Commodity Standards. Having witnessed and helped resist at least three efforts to abolish this important Government activity, we are aware of the disruptive effects, the impact on staff morale and the slowing down of standardization efforts during these periods when outside groups particularly were attempting to take over this important Governmental function. A firm statement of Congressional intent will ward off such approaches in the future. We respectfully urge that this statement be made a part of the record. Sincerely, Mr. FRANK R. HAMMILL, Jr., ROBERT H. NORTH, Executive Vice President. MILK INDUSTRY FOUNDATION, Washington, D.C., September 27, 1966. Counsel, Committee on Science and Astronautics, House of Representatives, Washington, D.O. DEAR MR. HAMMILL: On behalf of the Milk Industry Foundation, whose members process and distribute over 60% of the fluid milk and fluid milk products in the United States, we wish to make our views known on H.H. 17424. We have studied the proposed legislation in detail and support what we believe to be the basic objectives of the bill. While essentially the proposed legislation is "To promote and support representation of United States interest in voluntary international commercial standards activities. ." certain provisions of the bill seem to go beyond this and could possibly be misinterpreted. For example, under the broad authority given to the Secretary of Commerce it would be possible to abandon or reduce the effectiveness of the Office of Commodity Standards and thereby deny industry an agency which through the years has provided an effective and worthwhile program of engineering and commercial standards. There are in operation today many simplified practice recommendations for packages and containers used in the dairy industry which have made possible substantial savings to the consumer and afforded her the ease of purchasing many dairy products in standardized packages. Without the Office of Commodity Standards it would be doubtful if this association would continue its efforts in this area because of antitrust implications. Our other fear of the proposed legislation deals with the establishment of a clearinghouse for commercial and procurement standards. While the language of the bill authorizing such a clearinghouse is not clear as to where this necessary service should be located, we would urge it being maintained by a public agency. There is already established within the Department of Commerce such a clearinghouse and we feel that this activity is one which most logically should be carried out by the government. In connection with these two points just made, we are happy to endorse the statement of Mr. J. D. Ritchie who presented testimony before a Special Subcommittee last week on H.R. 17424. The presentation of Mr. Ritchie describes very well our concern with many of the provisions contained in the bill. Our experience with the workings of the Office of Commodity Standards has been long and fruitful to the industry we represent. Our only purpose in forwarding these comments is to urge the Committee to provide that these services be continued and not diminished by any language contained in H.R. 17424. We would respectfully request that our views be made a part of the record. Sincerely, JOHN F. SPEER, Jr., Mr. FRANK R. HAMMILL, Jr., NATIONAL FOREST PRODUCTS ASSOCIATION, Counsel, Committee on Science and Astronautics, House of Representatives, Rayburn House Office Building, Washington, D.C. DEAR MR. HAMMILL: Recently, we have reviewed the bill (H.R. 17424) presently before the House of Representatives and having as its stated purpose: "To promote and support representation of United States interests in voluntary international commercial standards activities, to establish a clearing house for commercial and procurement standards, and for other purposes.” The forest products industry joins with other industries in recognizing the desirability of furthering development of international standardization activities as an aid to the export and foreign utilization of our products. Although we have not, thus far, encountered significant problems in the area of cataloging standards or securing standards information relating to the products of our industry, the proposal to establish a clearing house for commercial and procurement standards may also be of value to some industries. We assume, however, that the responsibility of the clearing house would be largely that of dissemination of standards information. It is rather the broad general scope of H.R. 17424 that gives rise to some concern in the forest products industry. The similarity of provisions in this bill to proposals made within recent years for establishment of a national standards coordinating body is also of interest to us. These proposals generally tend to discredit the commercial standards program of the Department of Commerce which has served a number of divisions of our industry very adequately for many years. Therefore, while we support the principle of furthering voluntary international standards activities, we question the broad discretionary powers in the bill which could be used to effect major changes detrimental to commercial standards procedures presently utilized by our industry. Indeed, it has been reported to us that the existing Commodity Standards program under the Department of Commerce presently merits reinforcement in order to service industry requirements adequately. The forest products industry also supports the private standards promulgating bodies mentioned in H.R. 17424 and believes that government representation in these agencies should be carefully reviewed to prevent domination of general interest and private industry representation. Also, it seems possible that the sweeping authority authorized in H.R. 17424, including monetary grants "as may be necessary and without fiscal year limitation," to appropriate private standards bodies, could result in excessive governmental influence in private standards development activities. Sincerely, Hon. GEORGE P. MILLER, MORTIMER B. DOYLE. HOUSE OF REPRESENTATIVES, Washington, D.C., September 26, 1966. Chairman, Science and Astronautics Committee, House of Representatives, Washington, D.C. DEAR MR. CHAIRMAN: You will find enclosed a copy of a letter from my warm personal friend, Dean Wallace D. Trevillian, at Clemson University. I shall be most grateful if you can have Dean Trevillian's comments about your bill, H.R. 13786, made a part of the record; and in the event this bill is taken up, I shall appreciate it if you will let me know in order that I can advise Dean Trevillian at that time. DEAR BRYAN: This is in reference to the Miller Bill, H.R. 13786. First, it is my understanding that this bill will not come up for action this year but is likely to be acted on in the next session of Congress. My concern is thisI have reason to believe there will be organized effort to have the words "business administration" included in the bill as one of the "named disciplines." This might appear in paragraph 7, page 3, or under definitions on page 8, paragraph A. If and when such action materializes, I would like for you to consider inserting "industrial management" as a named discipline. |