is removed and it is "pure silk" after all the gum is removed, leaving only the actual silk fiber (or fibroin) remaining.

Now, leaving the above for a moment, I would advert to the "loading," or weighting of silks, some of the materials used in these processes being much more injurious than others and certain of such additions, when used to a small or modest extent, being relatively innocuous, whereas, if used in larger quantity or carelessly applied, they might prove most destructive.

If a statement has to be made of the proportion of "loading" in a fabric it is to be presumed that the reason for this would be that the buyer would judge that the greater the amount of weighting the less the life of the silk was to be, and the lower the price should be. One thing which makes a great difference in the matter of proportions is the relation which the weighting bears to the actual silk fibre which is in the material, for the gum of the silk, as stated before, does not have the valuable properties of the silk fibre. It will be apparent that it makes a great deal of difference whether the relation of the weighting is to a weight of silk fibre alone, or to a weight composed of part silk fibre and part silkworm gum.

For instance, supposing that we have two 1-pound lots of silk; one is 16 ounces of pure silk fiber—that is, the "boiled-off" silk; the other is composed of 13 ounces of pure silk fiber and 3 ounces of silkworm gum. Now, suppose that 8 ounces of weighting is added to each of these; in the case of the first, the loading would be 50 per cent of the weight of the fiber, and in the case of the second it would be over 61 per cent of the weight of the fiber, and yet in each case it would be 50 per cent of the weight of the "pure silk."

Each lot of raw silk may have a different soluble content from the one which has preceded it; the dyer can not control exactly the amount of weighting to be put on the fiber; the silk, under the influence of different mordants and dyestuffs may absorb more or less moisture from the air than would normally be the case; soap and oil, to an (exactly) unascertainable extent, is introduced into the silk by the "throwster" as a preparation for his operations of "throwing" or twisting; and silk varies in weight owing to atmospheric conditions and may vary in a very marked manner.

The cumulative effect of all these influences is great, and this renders it a hopeless task to determine exactly what the percentage of weighting is in any silk as compared with the weight of that silk, whether this weight be, or be not, complicated by the presence of silkworm gum. Also, colored silk must be dyed, and while the weight added by the coloring matter may be small, it is often by no means negligible.

The custom of the trade for the handling of silks is usually as follows: The manufacturer contracts with a raw silk importer for certain bales of raw silk. He generally does not see these, and buys entirely from sample, or description. He is furnished with information by the importer as to the size or thickness of the silk, and he will sometimes have the size, and frequently have the weight, checked off by "conditioning house" tests made on some bales selected at random from the lot. The silk is shipped (with the exception of such sample bales as may be sent to the "conditioning or testing house" for tests) direct to the throwster who spins or twists the silk, thus making it possible to dye it in the skein. As a preliminary to his operations the throwster soaks the silk in a bath of water containing some oil and some soap, and the practice of throwsters in this respect varies greatly. The silk takes up from 50 to 70 per cent of the soap and oil in the bath and may gain in weight from 1 to 7 percent, or even more, according to circumstances, though, for its proper working, only a small percentage should be necessary. After the throwster has completed his operations he ships the skeins of silk to the dyer, and the dyer gets his instructions from the manufacturer as to what weighting and colors should be put on the silk. As stated before, the dyer can not control exactly the manner in which the silk takes up the weighting, and therefore he requires a latitude within which he can work. For instance, silk will be ordered from 18 to 20 ounces, 20 to 22 ounces, 22 to 24 ounces, etc.; that is, for each pound of 16 ounces of thrown silk, as weighed on the scale at the time of its receipt by the dyer, the latter must return the silk correspondingly increased in weight. If it was ordered 22 to 24 ounces, for instance, the dyer would be obligated to return to the manufacturer a weight of dyed silk which should not be less than 22 ounces, nor more than 24 ounces for each 16 ounces processed, but may be anywhere between these two.

Now, the dyer in his operations has boiled off the gum from the thrown silk (as well as whatever soap and oil was added by the throwster) and has then

added weighting materials to the silk to bring it up to the approximate weight required, and it is then colored and, when finished, it is returned to the manufacturer, who, if he finds, on weighing it, that it corresponds with the weighting ordered, and if the color is right, accepts it and puts it into work.

The silk in its natural raw state may have had a very large content of gum, a very small one, or a medium one. The throwster may have increased the weight materially with soap and oil, or may have increased it very little, and therefore the amount of the silk fiber in the 16 ounces boiled off by the dyer may be, and is, an extremely fluctuating quantity. The manufacturer does not know, and never could know exactly what it was, and consequently could not state just what was the amount of weighting on his silk.

Within the limits of commercial practice silk so processed, with a full weighting, say 22 to 24 ounces, if it were tram, might in one case have an addition to the fiber of 65 per cent or lower, and in another case have an addition of as much as 90 per cent or higher, and the manufacturer would have no knowledge that there was a difference between the one lot and the other. See "Chittick." Silk Manufacturing and its Problems," 1913, page 34.

Taking the dyed and finished silk fabric, it would be a matter of extreme difficulty-I might say of impossibility (even if extremely large amounts of material were put under test) to chemically determine what the exact percentage of the weighting of the silk was, for it must be kept in mind that the dyestuff necessary to color the material, and which usually adds something to its weight, is not an adulterant, for, if it was, every colored fabric would be an adulterated fabric. As a matter of fact, no practical method of determining amount of weighting on silk, has ever been devised.

Such determinations are further complicated, in the case of silks, by the finish or dressing which is put on them. "Sizing is sometimes added to the warp or filling yarns of which the goods are made, to cause them to work smoothly and well in the looms. Sizing, generally of a gummy nature, is frequently added to the finished silk to impart a body or "handle" which it otherwise would not have, such sizings, or dressings, being of an entirely harmless character, although, of course, as they add to the weight of the material, they might be classed as adulterations, and they may add a weight up to 15 per cent or more. Then again, there are fabrics in which it is absolutely necessary that gum or stiffening, and a great deal of it, should be used, such as in the case of grenadines and veilings, where the uses to which they are to be put, and the character of their construction may make such a finish obligatory.

Now, the manufacturer of silk goods which have had some gum added to them in the finishing does not know what this percentage of gum is so long as it is within the ordinary limits of practice. It might be argued that by weighing the pieces before and after the finishing this could readily be determined, but, after finishing, the goods having been heated, smoothed, etc., and consequently being dryer, will, as likely as not, be lighter on the scale than before they were finished, instead of heavier, even if then retaining this addition of gum. Here again the silk manufacturer is hindered from knowing just what proportion of his goods is pure silk fiber, and in determining the content of silk fiber in the dyed silk by chemical analysis, the presence of these sizings tends greatly to confuse the result of the analysis. There is no known way of accurately determining the amount of chemical loading put upon the silk.

Another point to consider in this matter is the question of atmospheric moisture, for certain metallic salts with which silks are weighted may be non-hygroscopic while the silk material is very hygroscopic. Thus, if on a day of normal moisture there was 50 per cent of "tin" in a fabric, the remaining 50 per cent being silk (that is, silk carrying its normal content of moisture which will be 45 parts silk fiber and 5 parts moisture) it will follow that on a damp day, when the silk takes up more moisture, the tin will bear a relatively smaller proportionate weight to the total, and on an extra dry day will be a relatively larger percentage of the total. Remember in this connection that while silk will normally contain about 10 per cent of water, the moisture in it can be increased to over 30 per cent before it feels appreciably damp.

From the foregoing it will be seen that it is equally impossible for the silk manufacturer in common with the woolen manufacturer, to comply with the requirements of the bill.

We now come to the question of starches and finishes, to which, in the matter of silks, we have been referring in part;

In the woolen, linen, and cotton trades, practically all warps are sized with widely varying mixtures for the purpose of enabling them to be properly woven

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in the looms. The amount of size that each of these warps takes up is not readily determinable for a number of reasons. After the goods are woven, a sizing, or finish, or dressing must often be added so as to keep them smooth and firm and in suitable shape for marketing. The sizing added may be a very light one, or it may be an excessively heavy one, as in the case of certain low grade linens and cottons, and in this matter the manufacturer again has no practicable means of determining with accuracy just how much dressing is contained in his finished goods. This is complicated by the fact that the dressing in the goods absorbs moisture very differently from what the fiber in the goods does, and thus the moisture contained in the weight of the goods is an indefinable quantity, varying constantly.

If this sizing or dressing which, be it remembered, enters also into the warps of whatever goods may be made, is to be considered an adulterant, as in the case of linens and cottons, then there could hardly be, in practice, such a thing as a pure fabric of linen or cotton.

Next comes the case of printed goods; the colors used in printing have to be mixed with thickening pastes to make it practicable to use them on the printing rollers, and the weight that such starchy matters add to the fabric is material. In the case of many printed fabrics it is not customary to wash out these starches so it is almost impossible for the manufacturer to ascertain with precision what their weight actually is, and when he sends goods outside to a job printer to be printed, as is frequently done, he would have to make a chemical analysis of every piece received before he could make any reliable statements in the matter. Linens, again, lose about 20 per cent of their weight in bleaching, and, if starchy matters were added to them, the relationship between the weight of these and that of the bleached fiber will be different from their relationship to that of the weight of the unbleached fiber, the differences encountered here being akin to those encountered in the case of the silks some of which contain gum and some of which do not.

In connection with any provision for the stamping or marking of goods, I would point out the difficulty that would be experinced in the case of articles which were complete in themselves, such as handsome silk veils, or fine lace collars, or numberless other articles, the marking of which in a way not easily removable would simply destroy the salability of the goods.

From the foregoing remarks, which could be extended to an unlimited extent you will be able to appreciate my criticism of certain provisions of the bill, and will, I feel sure, be convinced of the impossibility of enforcing them in practice. In considering these criticisms, I beg that you will bear in mind that I have absolutely no interest to serve except that of the good of the Nation, and the good of the industry, and that I am heartily in favor of any legislation which would really be a corrective of the evils of misrepresentation.

Some things, however, might be done along the lines of this bill, For instance a silk that had been weighted in any degree, as compared with the absolutely pure-dyed silk fabric, whether with or without the natural gum in it, and into which no other fiber enters, could well be described as "all silk, weighted," without any attempt to show how much it had been loaded, and it is relatively easy to tell whether a silk has been "loaded" or not. Silk not loaded could be described as "all silk, unweighted." But, even here, comes the difficulty that it is absolutely necessary to apply some dressing or finish to the fabrics in this last process.

Again, fabrics composed of yarns into which both animal and vegetable fibers had been introduced might be so differentiated-and it might be, in this casethat approximate percentages of this animal fiber and the vegatable fiber could be stated, as these are chemically determinable. These composite fabrics could well be described as "mixed silk and cotton,' ""mixed wool and cotton," etc.

As I see it, the only real and practicable way to deal with this whole subject is to approach it from the standpoint of the British merchandise marks act, which without plunging into the maze of complexities which are encountered when it is required that goods shall be branded so as to show what they are composed of, simply penalizes the misbranding of them, and, in case it can be shown that they are misbranded, whether as to composition, country, or place of origin, or what not, it will bring punishment upon the offender.

APRIL 17, 1924.

JAMES CHITTICK.

JNew York World, April 19, 1924]

TRUTH IN FABRICS

About a dozen truth in fabrics bills are pending in Congress and are the subject of highly excited committee hearings. They are all of much the same cut of cloth, and that cloth itself is being more or less misbranded by its legislative manufacturers.

Something is to be said for a law against the misbranding of merchandise offered in interstate commerce. It would be simply an extension of laws common to the States against fraudulent practices în trade. But the leading FrenchCapper truth in fabrics bill is another matter. It not only compels manufacturers to brand or mark every yard of cloth they put out to indicate what it is made of and in what proportions-virgin wool, shoddy, silk, cotton or other material-but it establishes a great Federal system of licenses or permits which must be taken out by every textile manufacturer at home before he can begin to do business, and abroad before he can enter the American market. along with this system would go the creation of a great army of Federal supervisors and inspectors to eat up more of the people's tax money.

And

It is ostensibly a measure to protect the consumer. But Horace B. Cheney, of the Connecticut silk-manufacturing concern, says that 75 per cent of the misrepresentation takes place between the retailer and consumer.

Actually, however, the bill appears rather to be a device to compel people to consume more virgin wool under the high prices forced by the Fordney-McCumber tariff. If that is its object, then again would it be a failure, for it is the high prices of wool which drive people into the use of shoddy and cottonshoddy and not misrepresentation of the quality of the cloth.

Legislating against fraudulent practices is one thing. Legislating truth and honesty and temperance into people by fiat of law is another of which we are having altogether too much.

STATEMENT SUBMITTED BY JOHN W. HAHN, EXECUTIVE SECRETARY NATIONAL GARMENT RETAILERS' ASSOCIATION, NEW YORK

Mr. Chairman and gentlemen of the committee, the National Garment Retailers' Association, composed of hundreds of retailers of women's, misses', and children's wearing apparel throughout the country, is opposed to the passage of bill H. R. 739, introduced by Congressman French and submitted to your committee for consideration.

This association has been opposing truth-in-fabric legislation for three years, having appeared before the Senate committee which considered Senator Capper's bill, which is the companion bill to Congressman French's bill.

We feel now, as we have always felt, that the French bill is discriminatory legislation and will benefit no one but the woolgrowers and at the same time work to disadvantage against all others, including the public. We believe that it has never been the intention of Congress, and it is not now, to pass any legislation which would promote the interests of a few in one section to the disadvantage of others in other sections of the country.

The bill itself, we believe, is misbranded; it would not "prevent deceit and unfair prices that result from the unrevealed presence of substitutes for virgin wool in woven fabrics, etc., as claimed for it. On the contrary, we believe the passage of this bill would encourage malpractice and dishonest dealing.

To your committee it has been pointed out that there is nothing in the bill which would in any way compel those trade factors handling woolen fabrics to specify on the labels or brands the quality of the wool going into the fabric. There are many qualities and standards of wool, and simply to say that a fabric is 100 per cent virgin wool is in itself no recommendation or standard and would mean nothing in the way of protection to the public. On the other hand, such a law would mislead the public to believe that all fabrics or garments branded 100 per cent virgin wool are the best quality and superior to wool mixtures, though the intrinsic value of the mixtures may be greater than that of some virginwool fabrics.

So the passage of this measure, in our opinion, would place all virgin-wool fabrics on the same level, and dishonest traders so desiring could easily take advantage of the law to enrich themselves at the expense of the consuming public. To illustrate how the public might be deceived under such a law: Two garments of the same style and character, one of excellent virgin wool and the other of inferior virgin-wool fabric, would be branded identically the same. Naturally,

the public would consider them of equal value, and traders so desiring might easily increase the price level of the inferior virgin-wool garment to that of the better virgin-wool garment and extort an unfair profit. The public, of course, would take it for granted that they are fully protected under this legislation.

Then, again, if the garment of the inferior virgin-wool fabric were not advanced in price, would not this bill put the honest trader to a great disadvantage? We believe it would, as the honest trader would have great difficulty in convincing the public that the fabrics of his garments are of a better quality virgin wool than the fabrics of the dishonest trader, and the public would simply accept his statements that they are better as attempts on the part of the honest trader to excuse high prices.

Every factor in trade is striving to bring down prices so that there will be a general resumption of trade and a return to normal conditions. Pass this legislation and, in our opinion, instead of declining prices, the public will witness increased prices on all virgin-wool fabrics.

To us it seems obvious that this bill, in the interest of the woolgrowers, is urged for one purpose alone. That purpose is to increase the consumption of wool; and when you increase the consumption of a commodity you increase the price.

This bill intends to brand or label fabrics or garments as to the percentage of virgin wool. To say that a cloth is a virgin-wool fabric is no particular recommendation for it as against the fabric made partly of shoddy and virgin wool. To the trade shoddy means reworked wool; to the consumer it means an inferior substitute, and this misconception would only be confirmed in the opinion of the public by the passage of this law. Naturally, the public would assume that their conclusion that shoddy is inferior was justified, for otherwise, they would probably reason, the United States Congress would not find it necessary to pass legislation compelling the labeling of fabrics containing shoddy. So you would find the public more and more turning from those fabrics composed partly of shoddy and accepting only virgin-wool fabrics, regardless of the merit of the wool-mixture fabric and the quality of the virgin wool.

"Shoddy" does not mean inferiority. We ourselves find it almost impossible to determine, even by careful analysis, whether certain fabrics are made partly of shoddy and partly of virgin wool or entirely of virgin wool.

In our opinion the passage of this bill would add to the garment retailers' overhead by necessitating the maintenance of a vigilance force within the store to make certain that the provisions of the law are being properly carried out. A bureau of scientific research might have to be established to test the fabric of each garment, especially to ascertain the amount of cotton, if any, contained in the fabric before offering it for sale to be assured that the labels attached by the manufacturer are correct and truthful, for the burden of proof under the bill reste upon the retailer. In case of error it is obligatory upon the retailer to prove that the label attached to the garment going out of the store was the label passed along to the store by the manufacturer.

The committee will realize that the retailer might be wholly innocent of the offense, yet it would, in some cases at least, be difficult for the retailer to prove his innocence. The committee will also appreciate that retailers during the course of the year have returned to them hundreds of garments purchased by the public which in many cases have been worn. If the label was detached, as it probably would be by the consumer, what guaranty would the store have that the label and garment returned were associated when they left the store? Some garments would likely come back without labels. Many garments, especially those returned for no other reason than that they do not please the customer, are sold over again. How could the store protect itself on these garments if the labels had been removed?

If governmental protection were needed by the public-and we believe it is not-there are, we think, sufficient State laws to give the public adequate protection along this line without Federal legislation. We believe that the intention and desire of the stores to deal honestly is a greater safeguard to the public than all the laws of this kind that Congress could enact. Stores that are dishonest can not continue long in business.

But we respectfully call to the attention of the committee that 36 States in the Union now have advertising laws sufficiently embracing to protect the public against false and misleading statements, not only when used in the sale of woolen fabrics and garments of woolen fabrics, but all kinds of wares and merchandise. If it is the intention of the supporters of this bill to sincerely protect the public, all that is needed upon their part is to check up the offenders and prosecute them under the law in these 36 States and to urge the adoption of simlar laws in the remainder. For the information of the committee I am submitting