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Another factor which has lessened U.S. participation is the sheer magnitude of the task, both in terms of time and required financial

resources.

At present, it is necessary to raise funds for participation in international meetings, and for the support of secretariats, almost on a caseby-case basis. This is not a healthy situation simply because initiation of international projects, which tend to go on for a long time, and longrange planning are virtually impossible.

Another point regarding financial support must be recognized. It is the unfortunate case that much international standards work is of importance to industries which are fractionated, or which may not be represented by trade or professional organizations having the financial resources to support international work.

Again, short-term Federal support and continuing cooperation with private U.S. standards organizations such as the United States of America Standards Institute will provide the necessary "seed money" to bring about greater support by industry, trade associations, and professional societies for international standards and standardization activities.

Of almost equal importance is the establishment of a clearinghouse service where everyone interested in standards, both established and in process, may turn for information. There does not exist, I believe, in the whole world, a single comprehensive collection and dissemination source. This has resulted in expensive and unnecessary duplication of effort and a tragic dissipation of both scarce engineering talent and financial resources.

The task of establishing a clearinghouse is both complex and expensive. It is financially beyond the capability of any single private standards organization today. Involved is the necessity to collect all standards information, both domestic and international, including both industrial standards and Government procurement specifications and standards. A clearinghouse would include translation services; cataloging; indexing; information retrieval; and a broad gaged, fast, and dynamic dissemination program to assure utilization of standards and standardization information.

The Standards Institute has done a good deal of preliminary planning but much more needs to be done. The coordination and consolidation of both information and established standards will require the full cooperation and participation of all standards making bodies. Because many of the major standards developing organizations are members of the Institute-in fact, most of them-we feel confident that the job can and will be done. We prefer, quite naturally, to see this work done by private, voluntary organizations, with full and complete cooperation with Government departments and agencies.

We are moving ahead with our planning and will strengthen our capabilities in the months ahead. There will come, however, a time when Federal financial support will be required to establish the clearinghouse envisioned. This will be primarily in the development of information retrieval and dissemination systems. Such support will be possible with enactment of H.R. 17424.

I want to turn now to the specific provisions of H.R. 17424, and to offer certain suggestions designed to improve the legislation and more fully carry out its intent. In some instances, which I will spell out,

the suggested amendments are intended to clarify the purposes of the act and you may prefer to handle these matters in the committee report rather than in amendments to H.R. 17424.

We feel that the use of the term "commercial" to denote the type of standards activity and clearinghouse authorized by the bill is unfortunate because of its limited meaning. We suggest that the legislation will be strengthened by amending the preamble to read as follows:

To promote and support representation of United States interests in voluntary international standards and standardization activities, to establish a clearinghouse for standards and standardization information useful in commerce.

This may seem like a tiny point, but many persons in the standards field look upon "commercial standards" as applying only to specific products. What is intended, I am sure, by the bill is that all types of standardization activities must be promoted and supported. This would include many types of standards such as safety, acoustical, information, and terminology, which are not "commercial" per se but are certainly vitally important in "commerce."

Section 1 page 1, line 5-states a preference for voluntary standardization of products. We feel that the intent of this section must be carefully spelled out. It is seldom, if ever, in the public interest to standardize products. Standardization should include such characteristics of a product as definitions, methods of test, performance, and interchangeability of components, but standardization of products as a whole eliminates the competitive pressure for continued improvement and reliability. We suggest that the term "of products" be eliminated, or carefully and specifically defined in the committee report.

Section 2(a) states in part-line 18-"through any appropriate international organizations or bodies or with the standards organizations or bodies of any country, for the purpose of issuing international commercial standards."

While we recognize that it may at times be necessary to participate in the work of international organizations such as the United Nations or the Organization for Economic Cooperation and Development, or others, we believe that preference should be stated for participation in the recognized international standards making bodies, such as the International Organization for Standardization, the International Electrotechnical Commission, and the Pan American Standards Commission. This is suggested because the operating procedures of the above-mentioned groups assure participation by all parties at interest, including producers, distributors, users, and consumer interests, which is not necessarily the case in organizations primarily representative of specific government interest.

There are just two additional provisions of the bill which I want to mention in the interest of clarifying the present language.

Section 2(b)-page 3, lines 7 and 8-states that among other activities the clearinghouse should "coordinate and integrate standards and information pertaining thereto." We suggest that this provision be clarified to assure that the primary purpose of the clearinghouse is to coordinate and integrate standards information, including information on published standards, and not to coordinate actual standards development activities. The latter is, and should remain, the responsibility of each standards making body with coordination through the United States of America Standards Institute.

Section 3(c) relates to prices, fees, and so forth, for information furnished or services rendered by the clearinghouse. We feel this is highly desirable and that realistic prices, based on reasonable costs, be established.

It should be made clear, however, that prices of standards publications as such should be determined by the standards making organizations, not the central clearinghouse.

The United States of America Standards Institute appreciates the opportunity to appear and testify on this important legislation. We hope it will be enacted without delay.

I would be delighted to try to answer any questions which you may

have.

Mr. ROUSH. Thank you, Mr. McCune. We are grateful to you for appearing here today and giving us this very thoughtful and well prepared statement on the bills which we are considering.

Mr. Anderson, do you have any questions?

Mr. ANDERSON. Mr. McCune, on page 4 you say that "it has been our policy not to seek Secretariats." Would you care to elaborate on that point and give the reasons for it?

Mr. McCUNE. The Pan American Standards Union is quite recent. There are a number of South American countries or Pan American countries which have substantial standards programs. There are some that don't have any. There are different stages of development and it has been our feeling that they should be encouraged to undertake such work as is needed for standards development. Can I say it this way: There are world standardization bodies. Probably the prime purpose of COPANT would be for specific standards that would be primarily useful in the Pan American countries of this continent. We feel we should try to help with anything we can to assist their own standardization bodies. We would like to see them handle the secretariats for their own standards.

Mr. ANDERSON. To encourage them to take the initiative?

Mr. McCUNE. That is right, and this body will grow and become important. There is no question about it. Their next meeting is in Guatemala City in October with representatives from all over North and South America.

Mr. ANDERSON. It seems to me that we are talking about a rather major degree of participation by the Federal Government, and you make reference to people paying the fee for this clearinghouse type of service. I heard the figure yesterday that as envisioned the cost of this legislation would perhaps be in the early years around a million dollars a year. How does that strike you as far as the scope of the activity based on your experience with your institute?

Mr. McCUNE. Well, I haven't a good fix on what portion of the money would be required by the Department of Commerce. I couldn't speak to that at all.

As far as the increased participation in the development of international standards, this work will grow. Most of this is being carried by industry at present. I think the principal part of this bill is the clearinghouse provision. No one is going to establish a world clearinghouse of standards translated, abstracted, indexed, and some of these standards are about this thick [indicating] and they have to be

abstracted and finally put on computer tapes so people can find what they want. This is a massive job and a million dollars wouldn't even touch it. It would take years and years to get this done. The amount of money in this bill depends primarily on the rate you want to attack it.

And it also depends on the fact that there are not many people who know enough about this area. You can't immediately amass a staff of knowledgeable people, and you can't do this without knowledgeable people. People who did not understand what was going on would create more misinformation than information, so this is going to take awhile to do, and it should be done very carefully with highly competent people who have to be trained although there is a nucleus available, so I can't speak specifically to your question. I hope that is an

answer.

Mr. ANDERSON. Yes.

Would you care to make any comment regarding the matters brought up a few minutes ago, that is, the protection of small business interests, and the desirability of the Antitrust Division of the Department of Justice having responsibility in some of these contract areas? Mr. McCUNE. Of course, I haven't studied the Congressman's testimony, although I listened to some of it as I sat here. I wouldn't be prepared to make a statement that representatives of small business are not engaged in this activity until I've done some checking into it. I would like to point out, though, a point that I made in my testimony that very often one of the highly competent people working on a national standard may even be a private individual or a representative of a very small business because representation work on standards activities requires a lot of personal dedication. If you have a large group of people working on standardization, we would like to be able to send the man who understands it best in this group to represent the United States.

Very often this man is working for a local government. He has no funds, so we pick somebody else to go whose organization will support him, and this is what you have to do. The whole thrust of this bill is to help the situation.

As far as antitrust is concerned, I am not clear what is the point. Every time that you promulgate a standard to some extent it "hurts" somebody. Such standardization, I am sure, in the early days as a screw base on a lamp, that probably hurt somebody whose screw base wasn't the size it chose. Lord knows who chose it, but that was standardized long ago. And this will always be the case, and the procedures as you can see from our constitution of the United States of America Standards Institute, are that you first establish some sort of a group who are representative of the parties at interest. Nevertheless, you do sincerely try to get the parties at interest, manufacturers, consumers, and so forth. Some standards are important to consumers, other standards may only be important between two industries, as for example, a standard on a chemical that is made by one industry and bought by another industry. So, the parties at interest are not always in the same groups, but you try to establish who they are.

Then you establish committees or working groups who actually draft a standard and they come back to a sponsor and he submits it to this

committee and they vote. Then this vote comes up to a standards board which is also chosen to represent as best you can all interested parties, and before this board anyone who has an objection is recorded. If the person wishes to submit the objection in writing, our rules are that we must as a whole have it read to us and considered. We do not affirm a standard as a U.S. standard until these disagreements have been thrashed out and every last person who wishes to say "No" has a chance to say "No." We do not issue them until we believe there is a consensus. Consensus is not unanimity, but the consensus is the great majority of people who think it is right. This might mean that one single organization presenting a very valid objection would be enough to say there wouldn't be a consensus. This is a matter of human judgment, but our procedures really cover this.

Now, there is another area-I am not a lawyer-but if a group of people were to get together with the intent of establishing a standard and then forcing all others to manufacture nothing but this, that is clearly illegal; and if you were to do this, you would be in trouble with the antitrust laws immediately. But where you get together and have a voluntary standard, there is no compulsion. Competitive pressures may force people to do it, or in many cases they are forced by law where it is considered necessary. Laws at the local, State, or Federal level, are enacted to make the codes mandatory. Many of our American standards have been made mandatory by law which is the only way that you can legally make a standard mandatory, and this also hurts people. It must be remembered that when laws are passed you are probably hurting people, but if you are arriving at a consensus you are probably hurting the least number of people with the law.

That is the best way I can answer your question.

Mr. ANDERSON. Thank you very much. I think your statement is

excellent.

Mr. ROUDEBUSH. I also want to congratulate you on the excellence of your statement.

Just in terms of a layman, can you give me examples of where there is a glaring need to establish standards? Could you tell me some cases where you feel that need exists?

Mr. McCUNE. I think I can give you a good one.

Mr. ROUDEBUSH. All right.

Mr. McCUNE. I happen to be at the moment, in addition to my other jobs, chairman of the Nuclear Standards Board of the Institute. It was obvious 7 or 8 years ago that with the advent of atomic energy we would need many standards never before envisioned. The Nuclear Standards Board was created. It has a large number of sectional committees. It has a large number of sectional groups including many sponsoring these standards and we are just at present reorganizing our sectional committees in order to better handle the input that we get from the industry which you know is growing pretty rapidly, and from the Atomic Energy Commission which is participating freely.

That is an instance of where standards are obviously needed and a very clean one and this would be true of any new technology of major impact.

There are other instances. There are instances in which consumer standards are needed. As a matter of fact, I think it fair to say that as

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