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different fibers or other materials or substances of which such goods are composed in whole or in part, and, if in part, the relative proportion or percentage of each." The bill provides further that certain governmental departments shall determine by test whether such admixtures have been made and also the proportions of such admixtures.

Now, I beg to state, respectfully, but most emphatically, that, with all the knowledge at the command of the manufacturing industry, the determining of certain of these matters is an absolute impossibility, and that in many important directions the exact proportions are not known to the manufacturer who makes the goods, and can not commercially be ascertained even by him.

Amongst other things to which I would especially call your attention are the b'ending of various wool or other animal fibers, the weighting or adulterating of silk goods, and the increasing of the weight of various woven fabrics, cotton, linen, silk, or other, by the addition of starches or dressings.

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First, as to woolens: So far as testing is concerned, there is no known method of determining what fibers in a sample have already passed through a manufacturing process and what fibers have not; and if there were, the impossibility of determining how many of the thousands of fibers under observation in a sample had been previously manufactured and how many had not must be apparent. it be stated that fibers which had already been manufactured would appear short, broken, or injured, it can be answered that, in the processes of manufacture, new wool fresh from the sheep's back, may also be short, broken, injured, and otherwise badly handled, and very often is, and some wool, just as sheared from the sheep, will be short and broken.

Again, in certain fabrics, such as worsted knitted sweaters, for instance, long straight, and smooth wool usually enters, which wool has been very carefully gilled, or carded, and afterwards combed, and not only do these long fibers lie in the goods straight, true and unbroken, but the felting of one fiber with another is avoided. When such garments are worn out, and finally reach the waste dealer, and are torn up, and well oiled, the great bulk of the individual fibers, of which the yarns entering into them are composed, can be drawn out unbroken by mechanical processes, so that we recover them in practically the same condition that they were before they were spun, being still, long, straight, and uninjured, and also commanding a very high price in the waste market, as they are even then very much superior to a large amount of new wool fresh from the sheep's back.

If it is desired to put to the test the ability of anyone to determine between new wool and wool that had previously been reworked, it can be done by making up three samples, say, one of short length wool taken from the sheep's back, another sample of garnetted waste of similar fineness, or coarseness, recovered from manufactured stock that has been reopened by the Garnett machine, and a third sample in which these two kinds were thoroughly blended together. Such a series of examples could be submitted to as many technicians as you please and no one could tell what proportions of the new and old wool there are in the samples, and they might be so prepared that no expert on earth could truthfully take oath as to just what they were, and, in the case of the mixed one, that any mixture had taken place. In the pulling of wool by the liming process, short scraps of the wool from, say, to inch length will accumulate in the vat. When collected and dried, they are known as "vat skimmings" and are very short, dull, hard, and lifeless, and can only be used for the cheapest purposes. Yet this miserable material is pure wool direct from the sheep's back, which has never been through any manufacturing operations.

I would also draw your attention to the fact that under "mixed goods" you include all fabrics into, which any other animal fiber has entered: In some of the very highest and best qualities of woolen goods there is introduced mohair, and vicuna, the latter being the fine inner hair next to the skin of a small South American animal of the llama species, The introduction of a small amount of this into a cloth gives a silkiness of touch which for some purposes is considered very desirable, and I beg you to observe that the cost of this material is between $4 and $5 a pound. Mohair, also, particularly for women's wear, is freely introduced into certain woolen fabries to which it adds strength, durability, and brilliancy, and mohair is an expensive fiber. Why should there be a discrimination against the use of the hair of these and other animals as opposed to the hair of sheep?

Next, if a manufacturer was making a mixture of what you term "pure wool" and of other fiber which had previously been manufactured, and knew at the very beginning of his operations just exactly what his percentage of each was, he could

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not state with accuracy what the percentage of each would be in the finished cloth, which is what he would have to brand. In all the various processes of manufacturing, such as picking, carding, combing, spinning, warping, spooling, winding, weaving, burling, gigging, shearing, etc., a wastage of fiber takes place. Now, if the material provided at the start had in it 50 per cent of previously manufactured material and 50 per cent of pure wool, who can say what proportion of each will be represented in the waste made and collected (to say nothing of what is called the invisible waste, that is, waste which cannot be accounted for), and what proportion remains in the goods? Examine the wastes as you will and no determination can be come to and while it is practically certain that the wastage will not be equal, for, in fact, one or other of the classes of material used will give a disproportionate amount of waste, no one on earth can determine what it has been. Consequently the manufacturer who made his blend 50 per cent of each of the two classes of stock may have a finished product which contains 45 per cent and 55 per cent, or 48 per cent and 52 per cent or whatever you please, and yet under penalty he is required to state accurately what the proportions are in his finished cloth.

Again, let us suppose that cotton had been introduced into the mixture with the wool. It is quite true that chemical determination will show the approximate proportion of cotton in the final mixture, but as cotton has different hygroscopicproperties from wool (the "regain" of moisture in cotton being standardized at 8 per cent while the "regain" of carded wool and wool waste are both standardized at 18 per cent) it is evident that, according as the day upon which the observation might be made was a damp one or a dry one, the proportion of the two fibers to the total weight of the sample would be a constantly varying one.

The manner in which the influence of moisture upon textiles will affect these matters is neither academic or negligible. When moisture in a skein of worsted yarn—all wool, of course—may vary under ordinary New England conditions from as low as 7 to as high as 35 per cent of its total weight, often with a variation of 15 to 20 per cent in 24 hours, the importance of this consideration becomes apparent. (See "Tops," published by the Arlington Mill of Lawrence, Mass. (Riverside Press, Cambridge, Mass., 1898, pp. 66-67.)

Again, take the case of a weaver who buys woolen yarns from abroad and which are sold to him as all "pure wool" he will have to depend upon the statement of the foreign spinner, but our laws have no control over him, nor can we compel him to show his lot book to prove to us exactly what has gone into each blend which he has made.

The foregoing considerations will show that there may be great fluctuations in the real proportions of a supposedly known blend, due to varying wastage in manufacturing and difference in moisture, not only daily differences, but differences in the hygroscopic properties of the materials blended together and other differences due to the presence of dyestuffs, oils, or other substances in the material. We are therefore faced with the cold fact that no one, no matter what tests were made, could, from those tests, truthfully take oath as to the presence, or as to the proportions in a woolen yarn of certain fibers which would not come under the definition of your term "pure wool." Test samples from one part of a cloth will also vary as compared with samples from another part.

Now, your bill undertakes not only to compel the manufacturer to make positive and accurate statements in these matters where accuracy is impossible, but to make him suffer heavy penalties for his inability to do this impossib e thing. This would simply put a premium on dishonesty, for while the honest manufacturer would blunder along and make the most truthful statements he could, a less scrupulous one would make misstatements about his fabrics with the full knowledge that no legal proof could be produced to the contrary.

We now come to the question of silks. Raw silk as it is reeled from the cocoon is certainly silk-pure silk. In this silk there is a soluble content varying from perhaps 15 to 30 per cent of its weight and, in the majority of the silk produced, averaging from 16 to 26 per cent, although the silk of one country in this respect will differ from that of another, and all of the lots of silk differ among themselves. Whether in the piece goods form, if the goods have been manufactured from this raw silk or in the skein form, if the silk has first been "thrown" or twisted, this soluble content is usually removed by boiling the silk in soap and water. Be it remarked that the presence of this soluble content detracts from the ultimate luster of the silk, though it does not materially affect its strength, elasticity, or durability, yet it is part of the silken material spun by the silkworm. The silk is pure silk" before this gum is removed, and it is "pure silk if the silk has been soupled "that is, processed so that a portion only of the gum,

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.

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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.

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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.

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