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LETTER OF TRANSMITTAL

Hon. JOSEPH C. O'MAHONEY,
Chairman, Temporary National Economic Committee,

United States Senate, Washington, D.O. DEAR SENATOR O'MAHONEY: I have the honor to submit herewith a report on consumer standards which brings together for the first time the facts concerning Federal activities in the fields of standardization, inspection, testing, and research which refer to, or provide a basis for, consumer standards. To this are added chapters on similar activities by private agencies and on procurement methods and procedures of both Government and private agencies. It is an analytical inventory of our present resources for the development and utilization of consumer standards, supplemented by a discussion of how these resources have been utilized and by the statements and opinions of professional, trade, and consumer groups on that subject.

The monograph is the work of Samuel P. Kaidanovsky, a member of our staff and Technical Director of the Consumer Standards Project sponsored by this Division. It is based upon original research carried out under his direction. Miss Alice L. Edwards, also of our staff and formerly executive secretary of the American Home Economics Association, assisted in the preparation of the report and is the author of the chapters on consumer buying and on value of standards to consumers. Respectfully submitted.

D. E. MONTGOMERY,

Consumers' Counsel,

Department of Agriculture. OCTOBER 23, 1940.

IX

INTRODUCTION

Interest in consumer standards both on the part of the Government and of consumers is of long standing. Perhaps the first effective demonstration of this interest on a large scale was the passage of the Federal Food and Drugs Act of 1906, followed by similar State laws in the ensuing years. Numerous other Federal and State laws since, and a few before, have dealt directly or indirectly with standards for consumer goods and many State and Federal Government departments have exercised functions related to standardization.

In June 1933, the office of Consumers' Counsel was created within the Agricultural Adjustment Administration as an integral part of this Administration. The activities of the Consumers' Counsel consisted mainly of examination of marketing agreements and codes, research in connection with consumer problems arising under the Agricultural Adjustment Act, and investigation and publicity with respect to food and cotton textile prices to consumers. In analyzing proposed marketing agreements and codes, several principles were used by the Consumers' Counsel as a guide. Among them were included effective provisions for grading and standardizing products to insure honesty of labeling.

However, Governmental agencies dealing specifically with the general problem of consumer standards did not emerge until the establishment of the Consumers' Advisory Board of the National Recovery Administration. This Board maintained a continuous interest in consumer standards throughout its existence. The very first policy statements of this Board related to the subject of consumer standards, and Board committees early concerned themselves with the quality, grading, and labeling requirements of N. R. A. codes.

As a result, approximately 245 of the 556 approved N. R. A. codes and some 200 supplements contained provisions for, or at least referecces to, the establishment of standards, grades, and labels. The drafting, application, and enforcement of consumer standards were brought to discussion before the N. R. A. code hearings where manufacturers, distributors, and consumers were given an opportunity to freely express their opinions on the subject of consumer standards. Under this procedure the necessity for consumer standards was dramatized more than at any other time. A Standards Unit was first established by the Consumers' Advisory Board in January 1934. In October 1934 by administrative orders the standards work handled by several advisory groups was centralized in the Research and Planning Division of the N. R. A. Effective cooperation was achieved between the Standards Unit of the Consumers Advisory Board and the Research and Planning Division of the

On July 30, 1935, by Presidential Executive order, a new Consumers' Division was established in the National Recovery Administration.

X.R.A.

In it were consolidated the activities of three previously existing agencies: The Consumers' Advisory Board, the Consumers' Division of the National Emergency Council, and the Cabinet Committee on Price Policy.

With the termination of the National Recovery Administration on December 21, 1935, the Consumers' Division was transferred to the Department of Labor, and later designated as the Consumers' Project.

À Standards Section, established in the Consumers' Project, continued some of the research work on consumer standards and related problems, previously carried on by the Consumers' Advisory Board. The Consumers' Project came to an end on June 30, 1938. On July 1 there was created the Consumer Standards Project, a Federal WPA Project, which continued and enlarged the research done by the Consumers' Project in the field of standards for consumer goods.

With the exception of the last agency mentioned, which still functions under the sponsorship of the Consumers' Counsel Division, United States Department of Agriculture, the consumer agencies previously referred to are not treated in this monograph, which considers only existing agencies. However, they have been specifically discussed at this point because their activities contributed substantially to the work being done by existing agencies.

This monograph deals with standardization, inspection, and testing activities of the Federal Government and with the research work being conducted by various Federal agencies which refer to, or provide a basis for, consumer standards. The standards work of some of the most active private companies, technical and professional societies, and trade associations are discussed.

Standardization and simplification of products is also affected by State legislation; the range of State laws is given by two examples, one illustrating a field where almost complete uniformity has been effected, and the other where heterogeneity of requirements exist. These examples are fertilizer and new bedding and upholstery.

Procurement methods and procedures of the Federal agencies, States, counties, and municipalities are discussed, and results of surveys made on this subject, some especially conducted for the purpose of this monograph, are extensively considered.

Standardization procedure, definitions, and terminology used by different agencies are discussed. The procedures in setting up standards employed by various governmental and nongovernmental agencies are illustrated by charts. Further, the activities of some independent purchasing agencies, commercial testing laboratories, and commodity testing and rating agencies are described.

The extent and character of commodity information available to consumers, and the value of standards, grades, and informative labels to consumers and their effect on merchandising are also covered.

Finally, a few recommendations and policies made by various groups, such as consumers, retailers, trade associations, and professional societies, relating to consumer standards, grades, and labels, are also presented to indicate the viewpoint of various nongovernmental groups on the subject of consumer standards.

CHAPTER I

DEFINITION OF BASIC TERMS

The basic concept underlying the use of term “standard” is quite definitely established. The definition of a standard as given in Funk and Wagnalls “New Standard Dictionary" is: (1) “Any measure of extent, quality, or value established by law or by general usage and consent; a weight, vessel, instrument, or device sanctioned or used as a definite unit, as of value, dimension, time, or quality, by reference to which other measuring-instruments may be constructed and tested or regulated. (2) Hence, any type, model, example, or authority with which comparison may be made; any fact, thing, or circumstance forming a basis for adjustment and regulation; a criterion of excellence; test; as a standard of portion by weight of fine metal and alloy established by authority."

Dr. Lyman J. Briggs, Director of the National Bureau of Standards, points out the analogy of the intentional standardization as practiced by man (conscious deliberate selection) and standardization as a survival process (natural selection).

We need only glance at the rich background of standards in nature to gain perspective and obtain a better appreciation of present trends in standardization and their significance. In the same species of plants, fishes, birds, or animals, individuals resemble each other in the minutest detail of structure and function. So thorongh has nature been that each species may be recognized by the standanlized organs, functions, characteristics, or habits peculiar to each. At the same time, individuals exhibit definite distinguishing characteristics and develop in diverse directions to stimulate the natural processes of selection, survival, and evolution.

The more the mysteries of nature are dispelled by knowledge, the more is standardization revealed, as in the geometrical arrangement of crystal formation, predicted discoveries of new chemical elements, or the coming of a comet. We depend upon the meticulous regularity of the sun's appearance, the recurring pbases of the moon, and the perfectly timed rotation of the planets. We accept as indisputable facts the definitely established boiling and freezing points, the peculiar behavior of certain materials and the changeless normal properties of elasticity, strength, hardness, ductility, viscosity, refractivity, electric conductivity, permeability, and other properties of the elemental things of nature which man is constantly appropriating for his use.

The variations of color available to the painter are composed of parts of a Barrow band of spectral wave lengths and all of the artistry in music is conveyed through another small group of frequencies. And yet we hear no complaints that nature has carried standardization to extremes, that life is dull, drab, or dreary as a result of standardized chemical elements, standardized crystalline growth, or wave lengths, as in sound, radio, light, and X-rays.

In every direction we find standardization, whether we look to the orbits of the electrons about the atom, the constellations of the stars, the microcosm or the macrocosm, industry or sport, commerce or the arts.

The architect may be limited to one size of common brick but he has a choice del color, texture, and arrangement sufficient to produce an unlimited variety of structures and effects, while the accomplished limitation of dimensions gives him 1 basis upon which to start and relieves his mind altogether of the problem of the size of brick to be employed."

1 *Commercial Standards and Their Value to Business," p. III, CSO-40, U. S. Government Printing Office, Washington, D. C., 1940.

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