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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 was 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,
MORTIMER B. DOYLE.
HOUSE OF REPRESENTATIVES,
Washington, D.C., September 26, 1966. Hon. GEORGE P. MILLER, Chairman, Science and Astronautics Committee, House of Representatives, Washington, D.O.
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. With warmest personal re I am, Sincerely,
WM. JENNINGS BRYAN DORN,
Member of Congre88.
Clemson, S.C., September 20, 1966.
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 this I 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.
As I said, any action on this bill will be sometime off, and in the meantime, Dr. Whitehurst, Chairman of the Industrial Management Department at Clemson University, and I, will make sure that you understand the reason for our request. I hope to see you at some of the football games this fall. Sincerely yours,
WALLACE D. TREVILLIAN, Dean.
NATIONAL MACHINE TOOL BUILDERS' ASSOCIATION,
Washington, D.C., October 5, 1966.
DEAR MR. HAMMILL: In response to your letter of September 12, the National Machine Tool Builders' Association (NMTBA), a nation-wide trade association representing 164 companies engaged in the manufacture of machine tools, is glad to submit its views on H.R. 17424 to the Committee.
In accordance with your request, our comments are addressed both to the desirability of the policies set forh in H.R. 17424 and to the adequacy of the methods and techniques proposed in the Bill.
The NMTBA endorses the policies set forth in H.R. 17424 to promote and support representation of United States interests in voluntary international commercial standards activities, and to establish a clearinghouse for commercial and procurement standards. Our Association also supports and endorses the Statement of Purpose and Need of the U.S. Department of Commerce, which clearly outlines the importance and necessity of government support in the area of voluntary standardization.
Machine tools are high precision, power driven machines which are used to shape and form metal. These highly sophisticated devices are designed and manufactured to extremely fine tolerances. The importance of and need for appropriate voluntary standards are necessarily matters of great concern in our industry. Standards are means of technical communication which are essential for the promotion of economic development and the exchange of goods and services.
From its earliest days, our Association has supported the development of voluntary domestic and international standards appropriate to our industry. The NMTBA supports representatives of our industry to several committees of the United States of America Standards Institute, and at present we sponsor four representatives to international standardization committees meeting abroad.
The fact that standards adopted in other countries are not really voluntary in the sense that American standards are voluntary emphasizes the great importance to U.S. interests of representation in foreign and international standards making activities. Standards adopted by the government of a foreign country can have the effect of making illegal the sale or importation of non-conforming goods in that country without special permission. Thus, the promulgation of standards which are based on unrealistic or inappropriate criteria can create an effective non-tariff trade barrier which can be used to discriminate against the goods of other countries. The Commerce Department Statement makes it clear that representation of U.S. interests in countries promulgating international standards is vital to our national welfare.
Unfortunately, U.S. representation in these activities is far from adequate. It is true that our Association provides financial and informational assistance, and the USA Standards Institute assists in translation and correspondence for our representatives. However, the contribution of the time and services of the technical experts and engineers of our member companies for these activities is a major sacrifice for these relatively small companies. At best, our representatives work on international standards on a part-time and temporary basis. On the other hand, virtually every other major industrial country provides government support for full-time, paid representatives. Competition on these terms is, unfortunately, beyond the resources of the private sector alone.
In the light of the rapidly increasing amount of international activity in the area of standardization, there is a real need for U.S. teams to represent our
industry with adequate continuity and professional expertise. Ideally, these teams should be composed of technical experts and engineers who can properly articulate the interests of American industry and evaluate the commercial and technical significance of foreign proposals. It is clear that government support is essential for adequate representation in this manner.
Like other sectors of our economy, the American metalworking industry is also handicapped by inadequate information concerning established and developing international standards. We have a real need for a clearinghouse to provide full and up-to-date standards information as rapidly as possible. This is because manufacturing is cutting across more disciplines and becoming more complex every day. At the same time, technical and commercial standards are rapidly growing in number and complexity.
No single facility exists today for the collection and dissemination of all standards applicable to the products of our industry. The establishment and operation of such a clearinghouse operation would appear to be beyond the resources of any privately financed organization. Government support in this area would do much to assure the development of the principle of voluntary standardization which has been so successful for us in the past. It would also assist greatly in our international participation by providing rapid translation and dissemination of the various standards which are proposed and adopted.
The NMTBA feels that the approach taken in the enabling provision of the proposed Bill is adequate for present needs, both in the support of international representation and in the establishment of a clearinghouse facility. While our industry would prefer all such standardization activities to be undertaken on a purely private basis, it has become clear that the resources of private enterprise alone are inadequate to perform this task. It is time, we believe, for government support of the activities of the private sector. We feel, however, that it should be made clear in the Bill or the Committee Report that to the extent possible the Federal government should support, but not preclude or control, private activities in the field.
We also suggest that the declaration of purpose and enabling provisions of the Bill should be slightly revised to eliminate certain ambiguities in the language. In particular, we submit that the phrase “the development of voluntary performance and safety standards” should be substituted for the phrase in Section 1 "voluntary standardization of products." Our Association would never support or be a party to the standardization of products. This, we feel, would inhibit industrial progress and development and be inimical to the interests. and welfare of our society. Standards must be written on the basis of per-. formance and safety criteria which will allow manufacturers maximum freedom in the development of new and superior products.
In the same light, we would not support the standardization of "processes”. or "test methods” concerning our products. The standardization of a test method, rather than a test result, would limit the application of new developments in the testing and measurement field. For instance, in our industry a standard requiring the use of a micrometer in certain tests might rule out the use of far more advanced measuring devices such as laser interferometers.
We suggest that the first sentence of Section 1 of H.R. 17424 be amended to read as follows to eliminate these ambiguities :
“The Congress finds that the development and use of voluntary performance and safety standards by producers, distributors, users and consumers, and appropriate participation in international commercial standardization activities, promote the beneficial international and domestic exchange of goods and services of high quality, to the benefit of the general public.”
In addition, Section 2(a) should authorize the support of “United States participation in the development of international performance and safety standards of products and processes,” and Section 2(b) should authorize clearinghouse activities "for the collection and dissemination of performance and safety standards and government procurement specifications * * *.”
The NMTBA feels that the proposed legislation should make clear that activi. ties undertaken in the area of performance and safety standards do not violate the antitrust laws, and cannot be used as a basis for antitrust prosecution. We would suggest the addition of a new Section 6 of the Bill to this effect.
Finally, we feel that it should be made clear that the clearinghouse services authorized in Section 2(b) may to the extent possible be provided by private
organizations, such as the United States of America Standards Institute, and supported by the Department of Commerce, and need not be established and operated within the Department.
We would like to express our appreciation to the Committee for its excellent work in this area and hope that these comments will be of assistance. Yours sincerely,
JAMES A. GRAY, Executive Vice President.
ARMCO STEEL CORP.,
Middletown, Ohio, October 6, 1966 Mr. FRANK R. HAMMILL Jr., Chief Counsel, House Committee on Science and Astronautics, Washington, D.C.
DEAR MR. HAMMILL: We understand the House Committee on Science and Astronautics will soon complete the hearings on H.R. 17424. We have the following comments we would like to make for the record.
1. The Bill is much too broad in its concept.
2. It provides too much authority and leeway in the field of international standards to the Department of Commerce and the National Bureau of Standards.
3. This approach is completely different than at present. Today, such work is done on a voluntary basis by both Government and private indus try through the American Standards Association.
4. The powers outlined in Section 3 are far too broad. Your consideration of our observations and comments will be greatly appre ciated. Sincerely,
CHARLES E. STUTENBOTA, Assistant to Vice President, Director of Public Affairs.