standards approving ate loans. ITED STATES DEPARTMENT OF AGRICULTURE y for im ration. minis AGRICULTURAL ADJUSTMENT ADMINISTRATION Agricultural Adjustment Administration, United States Deent of Agriculture, does not formulate or promulgate standHowever, it does specifically use many of the standards have been promulgated by other bureaus in the Department and my instances uses modifications of these standards. Parity paysto producers of cotton, wheat, corn, rice, and tobacco are made he basis of an equivalent value according to adopted and lished grades. CONSUMERS' COUNSEL DIVISION e office of Consumers' Counsel was set up by the Secretary of culture as a division of the Agricultural Adjustment Adminison in June 1933. Although the functions of Consumers' Counsel he beginning were described in general terms, its activities soon. tallized in operation along the lines of (1) analyzing the probable t on consumers of proposed and operating farm programs, and senting its recommendations with respect thereto to the planning action divisions of the Agricultural Adjustment Administration (2) disseminating information to consumers on the operation of farm program, and on ways of increasing purchasing power ough informed and economical buying. istra Early in the evolution of Consumers' Counsel administration the pora-portance of the value of grading and standardizing to consumers a producers was recognized. Among the principles developed for examination of, and reports on, codes and agreements was the Latement at they should include effective provisions for grading and standardizing prodts to insure the honesty of weights and measures and of the product itself.1 Necessity promoted this evolution, and its relationship to standards. his is illustrated by the early history of Consumers' Counsel. When he processing taxes were imposed upon wheat and cotton, among other gricultural items, during the early period of the Agricultural Adustment Administration, wholesale and retail price rises ensued, with some distributors advertising that the increases were the result of the tax. In many instances it was found that the retail price rise was considerably more than the amount of the tax, while the buying public was led to believe that the tax was the entire cause. Recognizing the need for disseminating correct information, the Consumers' Counsel Division was set up to accomplish the task. Studies were made showing the effect of the per-bushel tax on wheat on the finished loaf of bread, and the effect of the per-pound tax on cotton on certain finished "Agricultural Adjustment: A Report of Administration of the Agricultural Adjustment Act. May 1933 to February 1934," p. 209, Agricultural Adjustment Administration, United States Department of Agriculture. 1934. cotton goods. This information was disseminated to the public and distributors were called into conference and presented with it. The sudden price rises of these taxed commodities were halted more or less effectively and tended to remain at general levels near those immediately succeeding the adjustment to the taxes imposed. However, Consumers' Counsel investigations and complaints from buyers indicated that, although price levels for given commodities remained stable, the composition and quality of the finished items often varied. For instance, the weight of the loaf could be, and sometimes was, reduced, or the amount of flour was decreased while moisture was increased; 2 or the weight of cotton shirts or overalls, or other textiles, was reduced for the same price line items. In the spring of 1940 the manufacturers of ribbons for hat bands. reduced the width of the band while maintaining the price. Also, stocking manufacturers, in the face of threatened rises in silk prices, increased the amount of rayon used, sometimes in the top and at others in the body of the stocking. Many similar examples could be furnished from the 1939-40 experience. The need for more uniform and continuing standards was pointed to as an assurance that consumers in their daily purchases might have a proper basis for arriving at accurate value judgments.3 Recognizing the importance not only of price variation but also quality variation, the Consumers' Counsel Division emphasized in its policies and its publications the need for extension of standards to promote more wise and economical buying. This policy has become an important phase of the Division's work. The activities of Consumers' Counsel Division in the planning, formulation, and administration of farm programs has involved consideration and use of various grades and standards, particularly in marketing agreements. While the basic crop programs may have attempted supply control, this was approached quantitavely, in that certain acreage reductions were made, thus reducing the supply by cutting off a segment of the producing facilities. It did not involve any deviation from grade or standardization other than that following the normal processes, although there may have been some slight tendency for the quality grown on better acreage to be higher. In the marketing agreement programs for milk, fruit, vegetable and nut products, in addition to the quantitative control, qualitative control has been employed. Control has been effected by limiting or prohibiting shipments of certain grades or sizes during all or part of the marketing season. In practice this meant, for example, that only milk which measured up to the specified standard, established in a local milk ordinance, could be marketed. In the case of fruits, vegetables, nuts, and other general crops, the shipment of certain grades such as "culls," or low-value grades, had been limited, or conversely only the grades which historically returned a price differential above a certain estimated minimum were allowed to be shipped. In most instances these grades or standards had been tested by industry practice and market acceptance and then were approved and promulgated by an authorized bureau of the Department, or by the States in which the program operated. Sometimes, but not often, modifi 2 "Bread Facts For Consumers," Consumers' Guide, vol. IV (3), p. 11, April 5, 1937. "Checking Your Weights and Measures," Consumers' Guide, vol. III (21), pp. 3-6, 8, November 16, 1936. cations of the promulgated grades and standards were provided in the terms of the regulation. The importance of proper grading and standardizing to insure better understanding of values in the market place has been emphasized by the Division personnel in their cooperation with other divisions of the Agricultural Adjustment Administration, and with other bureaus, in considering the applications and effect of programs. This has been accomplished through informal conference, memoranda, and formal hearings. As grades and standards for food products need to be revised from time to time to meet improvements in production, shifts in consumer preference, and changes in the art or science of grading and standardization, Consumers' Counsel Division personnel have assisted in presenting the consumers' viewpoint on important factors to be considered in such revisions for the following commodities: Eggs, beef, butter, lard, poultry, cheese, and citrus fruits. Here, as in marketing agreements and other programs involving standards, it is the function of Consumers' Counsel Division economists and marketing specialists to focus attention on the consumer aspects of pending issues and to argue the consumer point of view with respect to them. Producers and distributors are always represented during the program. Consumers usually are not organized and consequently are not in position to present their case adequately. Presentation of facts and substantial evidence to governmental agencies promulgating and developing standards is a direct responsibility of consumers if the standards are to be comprehensive and adequate. However, the task confronting the average group of consumers of acquainting themselves with all the technicalities and detail involved in each standard is formidable and difficult to obtain, unless they have a clearing house of information to assist them. To help fulfill this function Consumers' Counsel has conferred with consumer groups acquainting them with the need for specific standards and with pertinent facts and information. Consumers' Counsel has appeared to present the consumers' case in the considerations leading to the ice cream and ice cream freezer regulations for the District of Columbia. At hearings on standards for butter the personnel of the Division worked with consumer groups to assist them in the presentation of pertinent and substantial evidence relating to the desires of consumers and the effects of proposed standards on consumers. Much time and attention has been devoted to assisting consumers in presenting their cases before the Secretary of Agriculture at hearings on food standards, pursuant to the Food, Drug, and Cosmetic Act. This involves acquainting consumers with current practices, and in some cases malpractices, and with the technicalities of composition, quality, manufacturing techniques, and distribution, so that they may be able better to arrive at judgments as to what is in their best interests in the establishing of standards. It also means that the personnel of the Division must acquaint themselves with the economic and social effects of present and proposed practice and present evidence thereon for consideration in the standardizing process. The same applies to standards procedure under the Agricultural Marketing Service, the Bureau of Animal Industry, the Federal Trade Commission, and others. |