national picture and we changed our name from the Douglas Fir Plywood Association to the American Plywood Association because that reflected our area of operation more correctly, and I think this is likely the same. It isn't a scary proposition to us.

Mr. VIVIAN. What other private interests do you think will have control of the standards situation if the USASI is provided a significant amount of funds from the Government Treasury?

Mr. RITCHIE. If I may answer it this way, we are not so concerned that certain private interests will have the control. The record would indicate those that are the big factors in the organization, but we are concerned that within the organization could be interests that are not necessarily in accord with ours and they would have a very strong effect perhaps on our domestic or international standards and action might be taken by people who couldn't be considered wholly unconcerned with our interests.

Mr. VIVIAN. On page 6 you make the remark:

This bill would provide the impetus and the springboard for the abolition of the Government domestic commodity standards program and its transference to private interests as yet unidentified.

Who do you anticipate will control this program? You say "as yet unidentified." Can you identify those for me in any way?

Mr. RITCHIE. We are talking about American Standards Association. Mr. KINTNER. I think, to lay it on the table, it is rather obvious that the larger American corporations provide through their heads of research and other key personnel in research and development a great deal of the manpower that goes into the private standards program, and this is naturally so, but it does tend to give to the larger corporations within an industry a rather controlling voice, and not improperly so because the expert is there representing the large corporation.

We have felt in the American Plywood Association that the role of the Government in these programs gave the public adequate representation, and the consumer adequate representation, that perhaps the National Bureau of Standards experts were slightly less biased or tend to be slightly less biased than perhaps a representative of a par ticular corporation in a large industry.

Mr. VIVIAN. Are you familiar with the testimony given yesterday on behalf of Congressman John Dingell?

Mr. RITCHIE. Yes, I am; I have read that statement.

Mr. VIVIAN. Do you have any recommendations or comments to make relevant to that statement?

Mr. KINTNER. Well, as an antitrust lawyer, and I was General Counsel and Chairman of the Federal Trade Commission, I feel that while he has not been specific in his antitrust statement, that there is a certain degree of soundness about what Mr. Dingell has said concerning the possibilities, and I underscore the word "possibilities," of antitrust problems arising in the future where control would be vested over standards programs solely in the private sector of the economy. There are all kinds of problems that one might conjure up and perhaps we could better devote our efforts not to conjuring up the specific problems, the horrible examples that might be created, but merely insuring that there exist a few safeguards against the development of

these problems, and one of these safeguards is to have the Government have a seat at the conference table.

Mr. VIVIAN. Suppose we were to modify the bill to make it clear there must be small business and consumer participation in governing the use of any funds provided by the Federal Government, would this make your position on this somewhat more favorable?

Mr. RITCHIE. I think it would.

I might ask what you mean by small industry. I don't know how many voluntary standards there are. There must be a thousand or more. We have three, yet our industry is a billion-dollar industry working with three standards, and hopefully by November 1 we will have consolidated those three into one, so that we have simplified our procedures and so we consider our stake in this, of course, a very big

one.

Mr. VIVIAN. Having practiced as an electronics engineer, and been an officer in an electronics company, I am fairly familiar with some of the problems of this field. The number of standards is astronomical. But the question I ask is: Should we attempt to phrase the bill before us in such a way so as to make it clear that the representatives of large industry will not be allowed to dominate any operations supported by Government funds? Is it fair to say that you would like to see to it that large industries do not dominate standards making operations? Mr. RITCHIE. We feel that the present procedures that are administered by the Department of Commerce assure us of no dominance of that kind, so we are quite happy with the way the Department handles it.

If you mean that we would be willing to go along with the idea that the assignment be transferred to a private group if we were sure there was adequate representation in this private group, I don't think we would change our mind and say that that would be all right; we would still feel that the way to do it is the way it is being done, expand what needs to be done within the Department. Our record is excellent. We have an industry that from the time the first standard was developed until now has grown maybe fifteen or twentyfold. Only 15 years ago our annual production in sales were a billion and a half. By the end of this year it will be thirteen and a half, and the standards just had to be a part of that.

We are not objecting in any way to the idea that procedures should be reviewed, updated and improved, and in the course of updating the standard we have not done it less often than every 5 years.

Mr. VIVIAN. The bill before us is rather ambiguous in that it gives the Secretary of Commerce quite a bit of latitude. Would you feel that the continuation of the procedures that the Department of Commerce has been following to date, with representation on the standards committee, et cetera, that that would be entirely satisfactory if you were assured there would be a strong Government role and the assistance was contributory rather than dominating?

Mr. RITCHIE. I would say this would be satisfactory. We feel that the Government should be in control, and that any official status should be that of Government and not of a private organization, but we do not object to the private organizations per se.

Mr. KINTNER. The question you were getting at is: Would you vest it in the private sector and merely have representation of small business and Government and other public interests?

Mr. VIVIAN. Yes.

Mr. KINTNER. We feel that the control, the coordination and control, should be lodged in the Government with a maximum amount of cooperation from the private sector.

Mr. VIVIAN. I have the Evans Products Co. in my district. I don't regard that as small industry, but in the context of standards setting, would you say a company of that size is very active in standards setting or not?

Mr. RITCHIE. Substantially below the scale of control. We don't have in our industry any organization that produces more than 15 percent of the industry total and our organization is a one-ownership, one-vote type of thing, so I don't think any one of them by themselves would be considered controlling organizations.

Mr. VIVIAN. Are you concerned with the competition from foreign sources such as Japan?

Mr. RITCHIE. We are very anxious to have international markets and managed to win an "E" award for our efforts which were largely hard work, but we still have a long way to go to sell very much plywood.

We are first of all concerned that there be no change in the procedures for promulgating standards domestically. We would rather that the program that is implemented by the Bureau of Standards domestically can easily, efficiently, be expanded to international.

Mr. CONABLE. Do you participate in any of the voluntary standards setting projects that may be going on in your industry at this point? Mr. RITCHIE. We have not yet at this point; no.

Mr. CONABLE. Do you know if there is substantial international standards setting going on?

Mr. RITCHIE. We would urge there be. No question about it. Mr. CONABLE. You are not aware of any going on. It is not just that this country is failing to participate, is it?

Mr. RITCHIE. No, I don't think so, sir. The urgency hasn't occurred quite yet. The one exporter of some substance of a product like ours is Canada and they have done a good job. They have gone there before we have and we are playing a little catch-up game. In the long run we are anxious that standards be set so we are on some measurable basis with our competition.

Mr. CONABLE. You don't have the type of product where there would be substantial nontariff barriers, isn't that correct; it isn't like electronics, or is it?

Mr. RITCHIE. Yes, we have tariff barriers. We would not be exempt from tariff barriers.

I believe we have one problem with Canadians who have preferred status which I think is a 10-percent edge.

Mr. CONABLE. I am talking about nontariff barriers, the sort of thing which results from incompatible standards.

Mr. KINTNER. If I might add to the testimony at this point, I think that one of the great problems facing the plywood industry in export is the existence of building codes abroad which may not be wholly compatible with what they are able to produce in this coun

try, and these building codes can as they have in this country in the absence of some standards program can be a great impediment to building up the plywood industry.

Mr. RITCHIE. That is true.

Mr. VIVIAN. On page 4 you referred to misconceptions attributed to industries which prefer to use the Department of Commerce services.

What are some of the misconceptions?

Mr. RITCHIE. I think there are two. One was that somehow the industry would trade on the implication that a commercial standard that indicated Government sanction of some kind, it sounded like it was an official Government stand. We think that there is no evidence that that has been the case. Rather, the strength of the commercial standard-and one of the big reasons for doing it this way— is to add weight to our efforts to make sure the product is made correctly, and it does give us a strong tool with our own members to see that they conform to the standard, much better, for example, than the APA grade rules say. This is going back. There is no evidence we feel that the industry can trade on the fact it is commercial standard. The consumer rarely knows what that means. We would somehow try to impress the distributor at best and I don't think the evidence bears out this misconception.

Mr. VIVIAN. There used to be a DFPA trademark on your plywood. Mr. RITCHIE. That has not been replaced. The DFPA is the quality trademark. When we changed to the American Plywood Association, we put possible combinations through computers and many of them were hardly repeatable, so what we did was to assign the DFPA initials to our quality supervisory division. There is an APA or American Plywood Association trademark to which there is a little circle which we have had for so many years.

Mr. VIVIAN. We are, as you may be aware, considering the metric system to be applied to the United States instead of the heterogeneous mixture of measures. What would you do if you were to handle plywood on the metric system? I suppose you would consider these as standard size irrespective of their measure in metric units.

Mr. RITCHIE. Yes. I am sure that we would try to maintain the same standard sizes and then interpret them in whatever way we had to. This is simply because of the maximum size of equipment that it takes to make it. It goes clear back to the log in the woods and how many lengths you cut out of a 40-foot log.

Mr. VIVIAN. Do you manufacture plywood for use overseas which is gaged to metric standards?

Mr. RITCHIE. No. I think in our promotional program we could very well-we are a little early in interpreting our sizes according to the metric system same as we translate our promotional material in several languages.

Mr. VIVIAN. Do plywood firms overseas manufacture to metric sizes as opposed to English units?

Mr. RITCHIE. I am not sure, but the sizes are compatible, but I am not sure how they express them.

Mr. VIVIAN. Almost all plywood manufacturers across the world use English units?

Mr. RITCHIE. Yes.

Mr. VIVIAN. I would appreciate further information on this subject to be inserted in the record regarding standard usages around the world.

Mr. RITCHIE. I would be happy to do that. (The information requested is as follows:)

AMERICAN PLYWOOD ASSOCIATION,
Washington, D.C., October 5, 1966.

Hon. WESTON E. VIVIAN,

U.S. House of Representatives,
Washington, D.C.

DEAR CONGRESSMAN VIVIAN: Attached is the best information I can supply at present in answer to your question on September 22nd regarding the effect of metric measure on the promotion of plywood overseas. I have attached sample literature in which we base our technical data on the metric system.

At the time you asked the question, I said standard sizes are not likely to change. First of all, expensive production equipment is designed to produce these sizes. Anything larger than standard would not be possible in most present equipment. Any size smaller than standard would result in substantial production waste.

Perhaps more important, standard domestic plywood sizes are designed for present light construction systems. This means, 16 and 24-inch stud, rafter and joist spacing. As long as these modules remain as they are in this country, this would be our number one guide to standard sizes.

I hope this is the information you were seeking. If it prompts further questions, I would welcome another opportunity to investigate further.

Very truly yours,

JOHN D. RITCHIE, Regional Vice President.

AMERICAN PLYWOOD ASSOCIATION,
Washington, D.C., October 5, 1966.

Mr. FRANK R. HAMMILL, Jr.,

Counsel, Committee on Science and Astronautics,
House of Representatives,

Washington, D.C.

DEAR MR. HAMMILL: You will remember that, on September 22, 1966, I testified before a Special Subcommittee of the House Committee on Science and Astronautics regarding H.R. 17424. As a part of that statement, Representative Weston E. Vivian requested that I supply further information regarding the effect of metric measure on the promotion of structural plywood overseas. I now have received such information as is available from Mr. Harold Schadt, Export Manager, American Plywood Association.

First of all, the American Plywood Association is promoting the industry's softwood plywood products on the basis of metric measure at present. Technical literature has been prepared in English, German, and Japanese languages; all based on metric terms.

In Europe, particularly in Germany, there is a standard metric module used generally in all types of construction. This module is 1.25 by 2.5 meters, which is equal to 49.2 by 98.4 inches. This particular metric size has proven to be somewhat of a problem since we began our activities in Europe. Typical construction framing in Europe, however, involves a spacing of 60 centimeters (approximately 24 inches), so this has worked out very well with our standard width. Japan recently officially adopted the metric system. Because of this, at least one large Japanese contractor is ordering plywood panels one by two meters in size for concrete form applications. This size, of course, would be completely different from standard production sizes in the United States. On the other hand, plywood manufactured in Japan and the Far East is available in sizes which are about the same as standard sizes produced in the United States.

In addition to being manufactured in "standard" metric sizes, plywood is commonly available in 42, 5, 5% and 6 feet in width and lengths ranging upward from 2.50 meters to 12 feet, or longer, in metric increments. So, while the metric equivalents are not too different from standard sizes in this country, plywood manufactured in European countries does not correspond to standard sizes in our industry.