In those parts of a shoe where the wear is less severe, such as the counter and the inside of the heel, the manufacturer of low and medium-priced shoes can not afford to use the best quality leather without deteriorating the more important sole and top. He may use cheap and often spongy leather or a good substitute developed scientifically for the qualities required at such points, such as maximum imperviousness to water. The use of a substitute in such a case not only gives better service than cheap leather, but, because it is a by-product and less expensive than poor leather, it allows the manufacturer to use better merchandise in the sole and top. This is good shoemaking, because it produces a shoe with the maximum service for the price. The proposed bill is a screen behind which the unscrupulous manufacturer can hide his lack of scientific ability in shoe construc tion. That such substitutes are better than cheap leather will be obvious to you if you will take an ordinary horn fiber counter, for example, and compare with a sole leather counter costing considerably more, by putting both in a pail of water. The results are a demonstration. But, further than this, records kept for a period of years, upon a production of many million pairs of shoes, have shown that fiber counters of a superior quality gave a record of wear and service approximately twice as good as the sole leather counters made of the poorer quality of leather. The record would have been far different if sole leather counters of inferior quality had been used. Other instances might be adduced to the same effect. The objections to this bill, or any act for a similar purpose, are, in a general way, that the act would utterly fail to accomplish the purpose intended, and for that reason it would be unwise and unnecessary legislation. The obvious purpose of the bill is to protect the consumer against the substitution of inferior material in place of leather. Practically all the shoes manufactured to-day have, in some part of them, material other than leather, and for the most part this material is used because experience has shown it to be superior, for the particular purpose, to the ordinary kind of leather that would be used in its place, if the substitute were not employed. For illustration, steel and leather board are used for the shank pieces, ground cork and cement are used for forepart fillings, various preparations of canvas and gutta-percha are used for box toes, because they have been shown to be superior to leather for these purposes. In a great many grades of shoes a molded fiber board counter is better than a leather counter ordinarily used in a shoe of that grade. Interlinings for vamp and quarter made of felt and cotton flannel are used as doublers where leather would be entirely unsuitable. INCREASES PRICE OF LEATHER The effect of the proposed legislation, if enacted, will be to cause an increased use of poor leather, with consequent increase in the price of leather and in the price of shoes. While the proposed legislation obviously does not prohibit the use of substitutes for leather, it does put forward inferentially as the opinion of the Government that shoes so manufactured are inferior to shoes manufactured entirely of leather, of whatever grade. The enactment of the proposed legislation will unavoidably impair the confidence of the purchaser in shoes stamped or tagged as being made of substitutes for leather; will necessarily increase the sale of shoes made entirely of leather and will, therefore, increase the requirements of the country for leather for boots and shoes. The great majority of the shoes manufactured in this country are of low or medium grades. Practically all of these shoes are now manufactured, in part at least, from substitutes for leather affected by the proposed legislation. If the use of substitutes for leather were substantially abandoned, the inevitable effect would be an increase in the use of and in the price of leather. Such increase must be reflected in the price of shoes and will cost the American public, it is conservatively estimated, in excess of $5,000,000 per annum. This burden will fall largely, if not altogether, on the wearers of low and medium priced shoes, where it can be least easily afforded. REGULATION BY COMPETITION Competition now effectively regulates the construction of shoes in the interest of the consumer. The shoe industry is one of the few great staple lines of manufacturing in which the trust form of organization has made no headway. There are to-day over 1,300 separate and independent shoe manu facturing concerns in the United States. No pool, pooling agreement, nor combination of any kind has ever existed in the industry. Competition in the shoe industry has been keen and incessant, and has resulted in the consumer receiving the maximum value for his expenditure. If substitutes for leather were inferior in service to the cheaper grades of leather of an equal price, their use would have been ruthlessly eliminated by the inexorable laws of competitive business. No law has ever been placed upon the statute books which will act with the certainty and the swiftness and the unerring directness of the laws of natural competition. POINT II The use of materials other than leather for leather is in line with the conservation of our natural and economic resources. It permits the utilization of waste in the manufacture of by-products along the lines of the most scientific progress in industry. BY-PRODUCTS Substitutes for leather are manufactured as a by-product from scraps of leather which were formerly of no value. The utilization of such products as would otherwise be wasted is a direct economic gain to society and should be encouraged in every legitimate way. The utilization of waste in the manufacture of by-products is one of the great forward strides in industry which has marked the management of the present generation, second only in importance in the development of American industries to the inventive skill of our people. If the United States is to retain the place which it now holds in competition with other manufacturing countries of the world, it must continue its policy of utilizing every possible product. The effect of the proposed legislation will be to discourage the use of satisfactory substitutes made as by-products from the waste of the shoe and leather industry. Under such circumstances, to go back to the use of leather where substitutes can be properly used is like going back to hand methods and discarding our modern labor-saving machinery. POINT III The proposed legislation will undermine a valuable good will developed by manufacturers and wholesale and retail merchants throughout the country. OPPOSED BY MERCHANTS There are in this country approximately 600 wholesale shoe merchants and over 40,000 retail merchants handling boots and shoes exclusively, as well as approximately 100,000 general stores in which boots and shoes are carried for sale. Many, if not most of these merchants, have built up a good will (of inestimable value among their customers) through the style and reliability of the goods they have furnished them over many years. These merchants believe that their good will will be seriously impaired if this bill becomes a law. No adequate reason has been shown for the adoption of a policy believed to be so inimical to the interests of the merchants of the country and at the same time affording no benefit to the consuming public but on the contrary creating suspicion that shoes stamped or tagged are not equal in value to those not so marked, although in many cases superior in quality. POINT IV The bill would tend to perpetrate a serious and expensive fraud on the consuming public. It is our contention after reviewing the proposed bill from every angle that the enumeration of all articles other than leather used in the manufacture of shoes would be a burdensome formality, and would afford the purchaser no real information, and no protection whatever, but the most serious objection of all would be the compulsion under which some manufacturers would feel that they were placed to use leather exclusively under such circumstances, and would necessarily use a very cheap grade of leather which could be finished and disguised so as to have the appearance of good quality, while practically worthless. Soles cut out of bellies and heads, heels with soft spongy lifts, inner soles of two pieces of split leather, while entirely of leather might easily be inferior to any of the better class of substitutes. They would comply with the law, but would really perpetrate a serious and expensive fraud on the consuming public. Respectfully submitted by NATIONAL BOOT AND SHOE MANUFACTURERS' ASSOCIATION OF THE UNITED STATES (INC.). NATIONAL ASSOCIATION OF SHOE WHOLESALERS E. WALTER SMITH, President. NATIONAL SHOE RETAILERS' ASSOCIATION OF SEATON ALEXANDER, President. NATIONAL SHOE TRAVELERS' ASSOCIATION, (INC.). The CHAIRMAN. Are there any other questions? We are very much obliged to you, Mr. Hazzard. We will adjourn now until 10.30 to-morrow morning, when we will open on woolen blankets. (Whereupon, at 12 o'clock noon, the committee adjourned until 10.30 o'clock a. m., Saturday, April 26, 1924.) COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE, HOUSE OF REPRESENTATIVES, Saturday, April 26, 1924. The committee this day met at 10.30 o'clock a. m., Hon. Samuel E. Winslow (chairman) presiding. The CHAIRMAN. The committee will be in order. We will hear from a representative of a branch of textile workers who do not make textiles for apparel purposes. I believe the representative who is here is to talk on blankets. Will you please give your name, mail address, and the capacity in which you appear. STATEMENT OF MR. W. N. GIVEN, VICE PRESIDENT PEARCE MANUFACTURING CO., LATROBE, PA. Mr. GIVEN. I am speaking for the American Association of Wool Blanket Manufacturers. The following discussion is presented by the standardization committee of that organization, prepared by myself and Mr. J. J. Pearce, chairman of the committee, with the expressed approval of the members of the association. Mr. Pearce himself expected to appear, but an unfortunate accident prevented him from doing so. Keeping in mind the expression of the committee during yesterday's session, which indicated that they were not interested in repetion of facts already made clear in testimony previously presented, I will attempt to confine my remarks to only such statements as will direct your attention to the application of the legislation under consideration to our particular industry. I would call your attention, in passing, to the fact that up to the present all the testimony introduced has dealt with clothing materials. In addition to wearing apparel, however, the French-Capper bill includes, to quote from the bill itself, "every manufacturer of woven fabrics purporting to contain wool." 99564-24 -14 In preparing my statement, I have attempted to be brief. With the permission of the committee, I will follow my outline very closely in the interest of saving time. Since the committee has from time to time during these hearings asked the witnesses whether or not they wished to be interrupted with questions during their testimony, may I request that I be permitted to furnish my brief before questions are put to me? A word only concerning the American Association of Wool Blanket Manufacturers. It has as members 20 mills representing, as a conservative estimate, about 60 per cent of the wool blanket loomage of the United States. In presenting our case in connection with the so-called "Truth in fabric" bill, H. R. 739, we wish first to subscribe to all the features of the general presentation offered by Gen. John P. Wood. In our particular branch of the industry all of the points stressed by him are vitally effective to a greater or a lesser degree. In supplementing, or, perhaps better, in expansion of certain of his contentions, we respectfully submit the following: If it were possible to brand woolen goods so that we might have what the name of the bill promises, namely, "truth" in fabric, and if this bill could be enforced with any degree of justice and assurance, our association, standing as it does for the highest ideals in manufacturing, would most assuredly heartily subscribe to it. It has been shown, however, by convincing testimony, that the enforcement of such a law would be impracticable and even impossible. We will, therefore not dwell on this feature in our presentment. What is the purpose of this bill? Apparently to indicate to the consumer the quality and value of the fabric she is buying and to protect her from misrepresentation. It is based on the premise that all virgin wool is by nature superior to all reworked wool. Such an assumption is, however, as you now realize, untenable. The use of reworked fibers obtained from rags or clippings is negligible in the manufacture of bed blankets. The use of garnetted stock, however, is common. Under the French bill these garnetts are classed as reworked wool in spite of the fact that they are stocks reclaimed from threads which have never been in service and which in many cases have never left the mill. A blanket of, let us say, 50 per cent virgin wool of a good grade, combined with the same amount of garnetted stock of equal or better quality, may be manufactured at a given cost a blanket which is in every way serviceable, warm, and which represents as nearly as it is possible to manufacture the best quality of merchandise at that given price. On the other hand, a blanket of 100 per cent low-grade virgin wool, foreign or domestic, can be produced at a much less cost, but the resulting product gives neither the service, warmth, nor comfort represented by the blanket marked 50 per cent reworked stock. Now, what is the result of the application of a bill like the one under consideration in such a case? The consumer who is uneducated in textile values is instantly prejudiced against the superior article because it is marked 50 per cent reworked wool. Is truth in its real sense championed or perverted? If the blanket manufacturer could substitute virgin wool of the same quality for the reworked wool now used, and if the resultant rise in price were reflected in the service, warmth, and comfort of the product, no reworked stock would be used. But such is not the case. The increase in value, due to such a substitution is not at all in proportion to the increased cost of manufacture. Let me illustrate. Using as an example the blanket mentioned above, made of 50 per cent virgin wool and 50 per cent garnetts, if virgin wool of the same quality were substituted for these garnetts, the raw material would cost the manufacturer approximately one-sixth more. This additional manufacturing cost would of necessity be reflected in the selling price. Remembering that in distribution this blanket usually passes through the hands of the commission agent, the wholesaler, and the retailer before it reaches the consumer, it is at once evident that the resulting percentage charges for handling by each one will pyramid this increase to a very considerable figure. Yet the blanket itself represents little greater value, and as a matter of fact is not worth intrinsically 50 cents more to the consumer. Another point, the garnetts made from left-over threads, blankets mechanically damaged in manufacture, and similar sources, are now reclaimed and returned to the process. Deterred from such a policy of conservation by a law which would necessitate the labeling of the resultant product as containing a certain percentage of reworked wool, this perfectly good stock of identical quality to that contained in the blanket itself becomes waste, and the additional virgin wool which must be substituted to take its place becomes an additional charge to the final purchaser. From every viewpoint, therefore, the consumer must pay the ultimate cost of such legislation. Blankets, as well as all other woolen fabrics, are made of stocks carefully selected as to fiber, staple, grade, color, tensile strength, luster, curliness, the amount of black hairs or dead hairs called "kemp," and myriad other even finer distinctions difficult to enumer Also, where a domestic wool is used, a foreign wool or even another domestic wool of the same grade from a different part of the country can not be substituted and still retain the same standard of quality. The question has been asked if wool can not be graded in some manner as A, B, C, etc., or 1, 2, 3, numerically. If diameter of fiber alone were the measure-yes. If length of staple by itself were the factor-yes. If tensile strength, or shrinkage, or curliness, or any single one of the other measures of quality-most assuredly. But any standard attempting to indicate even vaguely the cumulative effect of all the contributing factors affecting quality--obviously no. But admitting for the moment the impossible assumption that such grading could be achieved, how would a brand indicate the resultant quality of a blend of several of the established grades; and, if you will go even further into the analysis, when the cloth is woven, how are you to indicate these compound values of the warp and of the filling separately, for in most cases they represent a different blend. Some time ago, in our own experience, it was found impossible to purchase the grade of domestic wool fulfilling all the requirements necessary to produce the standard product we manufacture. A certain wool house submitted a sample of South American wool as a possible substitute. By every measure of judgment of an expert buyer the wool was identical with that previously purchased, with perhaps the advantage that the foreign wool was slightly whiter in color. |