can scarcely be said to have two ends. Differing in strength as greatly, as also in many other characteristics which make some suitable for certain uses for which others can not be employed at all.

The few specimens shown here merely indicate in a very general way how comprehensive and how very indefinite the term virgin wool is.

The French bill not only treats all these differing kinds and qualities as equally worthy, one with the other, but it also assumes all, even the most useless, to be superior to any other wool fiber that is not inincluded within the heterogeneous group designated as virgin.

Here are some specimens of the raw material which it is the purpose of the bill to discriminate against by capitalizing a popular misconception:

The first is tailors' clippings, the pieces left over after cutting from the cloth the parts of garments. This is new material, has never been used. The amount of such clippings of fresh cloth that comes from the cutters' tables in the United States in a year, is upward of 13,000,000 pounds; one of the chief sources of supply for reworked wool. These clips are by machinery raveled into the separate fiber, like this next sample, which is reworked wool. Compare it in length, strength, softness, and warmth-giving qualities with many of these inferior virgin wools.

Senator Gooding, well known as a woolgrower and virgin-wool expert, has testified that reworked wool from new clips like these is practically as good as virgin wool. (Hearings Senate committee on S. 799, Sixty-seventh Congress, first session (1921), pt. 1, p. 231.) The fiber obtained from certain kinds of soft knitted material is even better. Such for example as this which is raveled out of material like this.

A still finer quality of reworked wool is this garnetted thread waste made from pieces of soft yarn like this sample, which have to be broken from the main threads during various operations of manufacture. Reworked wool of this character is not only superior to the large quantities of inferior virgin wool of which specimens have been shown to you but is also superior for clothing to much good fleece wool of the coarser grades. For instance, it is, as you can readily see, distinctly better than this variety which is good and strong, but lacks the softness and fineness necessary to make desirable fabrics for human clothing. While garnetted threads like this material has, besides length and strength, the requisite softness and fineness to make close, compact, warmth-retaining goods.

If to the quantity of fiber from new clips, which Senator Gooding conceded to be as good as virgin wool, there is added the quantity of the still better fiber from garnetted yarn and knit stock, the excellence of the reworked fiber used in clothing will be realized. In this connection it is to be noted that reworked fiber of the inferior grades is employed in large quantities for other purposes than clothing, being a component of the lower-priced rugs, carpets, of horse blankets, and in many kinds of packing, lining, and felt for mechanical and building purposes, and for a great variety of other uses.

If virgin wool did always mean good wool, a certificate that a fabric or garment was made of such wool would give no assurance of excellence. Much more important than the fiber content is the structure of the fabric and its fabrication. Durability and satisfaction

depend upon many other things besides the fiber. A few illustrations of many that might be given will make this clear.

This cloth is made entirely of virgin wool of excellent quality, but is obviously of poor quality, because of its poor construction. The obviousness of its defect would not, however, be apparent when made up into garments and lined. It is more readily seen when you handle it in the piece. It might be given a better appearance without at all enhancing its durability, by increasing the number of threads in one direction.

Worsted serge is probably more extensively used for men's suits than any other one cloth. Here are three samples of serge such as you are familiar with. Each is made of pure new wool of a fine quality. They are all of the same weight, have the same number of threads to the inch, and are so identical that when made into garments an expert could not distinguish one from the other. Yet there are differences in construction, which influence their cost and their endurance. In one the threads, both lengthwise and crossways, warp and weft, are of two strands of yarn twisted together. Another has the twisted yarn in the warp, but the cross threads are of a single strand, whole the third has a single yarn in both warp and weft.

Unsatisfactory wear is commonly attributed to the use of shoddy. It is nearly always due to other causes. To take but one example of the many that have come under my notice, recently. This sample is a bit of overcoating of a kind that has been favored by the public during the last two or three years. It has a long nap, giving a shaggy appearance to the surface. To produce the nap, the surface fiber has to be pulled up from the body of the cloth by passing it over cylinders which are covered with fine sharp wire, or with the spines of vegetable teasels. The fiber thus torn loose has but an indifferent connection with the fabric, so a moderate amount of friction will wear it off, leaving the cloth with a worn or threadbare appearance. This particular specimen happens to be of a fine quality of imported cloth which sells at wholesale for $8.50 a yard. The raw material is of the best. It was fabricated in one of the most celebrated mills in Europe, and is a splendid piece of workmanship of its kind. But the goods have caused wearers much disappointment and dissatisfaction because they soon become threadbare and shabby. But when cloths of this character are fashionable the public will have them in preference to other kinds, the serviceability of which has been tested by their own experience. And when they wear badly the fault is mistakenly attributed to the use of shoddy.

It is a fact, well known to those of extensive experience in the industry, that defects arising from the nature of the fiber content of woolen clothing are comparatively unknown. Defects due to unsuitable construction, to improper finishing, to poor dyes or poor dyeing, and to various other technical faults, are not uncommon.

But in the many discussions of this subject before committees of Congress during the past 20 years not one single sample has been exhibited of goods or garments that proved unsatisfactory in use because a part of the fiber was reworked wool. For a long time makers of woolen goods and wholesale buyers of such goods for manufacture into garments have jointly maintained a bureau for the adjustment of differences arising between buyers and sellers, concerning oods which are the subject of their transactions. At the hearing

held by the Senate committee in 1921 the head of that bureau, Mr. William Goldman, testified:

I have not heard of a single instance where any case brought before the board had anything to do with the fact that the fabric contained reworked wool. * * * Our complaints that come before that board have largely to do with the construction of the fabric. (Senate hearings pt. 1, p. 234.)

This other sample is also an overcoat cloth, made wholly of reworked wool or shoddy; but finished compactly by fulling, and with a close surface. Its cost was $2 the yard, less than one-fourth the price of the first.

Both samples were tested together for abrasion or surface wear, by means of a machine designed for the purpose, which rubs the surface of the specimens under test in like manner and degree. If you will examine both samples at the places where the tests were made you will see how poorly the $8.50.virgin-wool cloth compares with the $2 one of reworked wool.

Before leaving this branch of the subject let me show you these three specimens of overcoat cloth, they are similar in weight, structure, and finish. One is made wholly of virgin wool and one wholly of reworked wool. Test them in what way you will. The official tests favor the one made of reworked wool.

In passing, it should be mentioned that reworked wool is generally used in conjunction with new wool, each contributing certain needed qualities and characteristics. I have selected these specimens of all reworked wool to make the most convincing demonstration.

In this connection I will ask Mr. Humphreys to also show an overcoat made entirely of reworked wool, which he wears habitually. How would such a law be enforced? It is not possible by any chemical, microscopic or other tests to distinguish between virgin wool fibers and reworked wool fibers. The truthfulness of the statement on the label can not therefore be checked by analysis.

When the Senate committee held hearings on similar bills in 1921 we requested the committee to have a collection of samples analyzed by the Bureau of Standards, and at the chemical laboratory of the Department of Agriculture. After the samples had been left with the committee for several months, the chairman stated it had been decided not to have the tests made because the committee was convinced that it was impossible to ascertain by any examination what were the proportions of new and reworked wool in any given sample. Officials of the Bureau of Standards and of the laboratory of the Department of Agriculture have testified before committees of Congress that it can not be done. Representatives of the customs service, through the Secretary of the Treasury, have also testified to that fact.

Upon learning of our tender of samples for such analysis a professor in one of the western agricultural colleges expressed a desire to analyze the samples and was supplied with a set for the purpose. Somewhat later a professor in one of the eastern colleges, who is an expert microscopist, had an article in the Scientific American in which he explained how such examinations are made. And it was on the basis of that article that the microphotographs which Mr. French exhibited to you were made. He called your attention to the difference between the scales on one fiber and another. It is necessary to know first of all that the scales on wool vary in proportion to

the coarseness of the wool. On very fine marino wool they are very obvious, and very numerous and close. In proportion as the wool is coarser, the scales become less obvious and less numerous, and as the wool approaches the character of hair there are no scales at all. So that, in order to make such a comparison as was submitted in the two microphotographs it would be necessary to know first of all they were wool of the same degree of fineness.

As to the wearing off of the scales, the processes of worsted manufacture, whereby the fibers go through hundreds of different operations in constant friction with each other, would probably produce more wear on the scales of fine wool than any ordinary amount of usage which clothing is subjected to. And, of course, the large quantity of new tailors' clippings, of garnetted thread waste and of garnetted new knitted stock have not been worn, and the scales of their fibers are no more injured than any virgin wool that has passed through the various operations necessary to convert raw wool into cloth.

The professor who had the article in the Scientific American was also supplied with identical samples cut from the same pieces as those sent to the western college.

Here are the results of the two examinations. They agree with each other in practically nothing. Not one sample is correctly reported by both. The discrepancies are frequently as much as 100 per cent and the average for both examinations for all of the samples is more than 50 per cent wrong. By the law of chances anyone should be able to guess as nearly right without seeing the goods. I have here the samples mounted with a summary of the date, which I will submit to the committee, and shall only briefly refer to them

now.

In the first report the warp and weft of the goods was actually 100 per cent new wool. College A reported 5.4 per cent new wool and 94.6 per cent reworked wool, although it was all virgin wool. College B reported 100 per cent new wool, with probably some reworked wool. I do not know just how, with 100 per cent new wool, they found also some reworked wool. In the report the weft is practically the same, with the exception of a very small fraction.

In the next sample, the actual content of both warp and weft, is 10 per cent new wool, 90 per cent reworked wool. College A reports 50.02 per cent new wool; 49.8 per cent reworked wool in the warp; and in the weft, of exactly the same yarn, 31.5 per cent new wool; 68.5 per cent reworked wool. College B reports 100 per cent new wool. Actually it was only 10 per cent, the reworked wool. The weft, exactly the same yarn, "new wool, none; reworked wool, 100 per cent." Two yarns exactly the same, made out of the same mixture, one of the analysts reports 100 per cent new wool, and the other one reports no new wool, 100 per cent reworked, the actual fact being 10 per cent new and 90 per cent reworked.

The next sample contains 100 per cent new wool, both warp and weft. The first examiner reported it was 424 per cent new wool, 57.5 reworked. The other examiner says of the weft, 46.3 new wool, 53.7 reworked. The college B report, 100 per cent new wool, both warp

and weft.

The next one contains 75 per cent new wool, 25 per cent reworked wool. The first report says 50 per cent in the warp; for the weft, exactly the same kind of yarn, 17 new, 83 reworked. College B

reports, warp and weft both-he did discover that they were the same kind of yarn-20 per cent new wool, 80 per cent reworked. He had 20 per cent where he should have had 75 per cent. per cent where he should have had 25.

He had 80

The next one contained 100 per cent of new wool. The first report stated that it was so closely fulled (as overcoat cloths usually are) and the fabric so felted together, which is one of the conditions requisite to giving a warm overcoating fabric, that it was impossible to analyze it at all. The other analyst reported 25 per cent new wool, 75 per cent reworked wool; being in fact 100 per cent new wool.

The

The next specimen actually contains 87.5 per cent new and 12.5 reworked wool. The first report gives 57.8 and 42.2 per cent. second report takes two different threads out of the fabric, both of which were exactly alike in the mixture, made out of the same kind of fibers. One is reported to be 100 per cent new wool and the other 100 per cent reworked wool, the fact being that both yarns were 87.5 per cent and 12.5 per cent. Both examiners wide of the mark, and one of them finding widely different components in two yarns of the same composition.

If the labeling can not be checked by analysis, the only other means of enforcement is by inspection during the process of manufacture. To do that effectively would require an army of inspectors on constant duty and the inspectors would all have to be textile experts. If the Government did incur the enormous cost of inspection it would still be true:

That the law would not benefit the consumer in the slightest degree for reasons which have already been made plain.

And it is also to be noted that imported goods would not be subject to such inspection at the source, because our Government would have no jurisdiction over foreign mills.

Mr. French recognizes the impossibility of determining the nature of the fiber content by analysis or test and relies confidently upon inspection of the manufacturer's records to prove violation of the law. If he had a more intimate acquaintance with the conditions under which manufacture is carried on he would realize how impossible it would be for the Government to successfully prosecute suspected violations by such means.

If the manufacture of clothing was an integrated industry from raw material to finished product, and if each establishment made but few varieties, it might be possible, though difficult, to develop the facts by examination of mill records.

As the finished garment is the final product of numerous branches of industry, and as each branch deals with a wide variety of semimanufactured products and raw materials, it would be hopelessly impossible to trace the component raw materials back from the retailer through the records of all the intermediate stages of manufacture. Let me illustrate by a practical case. A suit of clothing sold by a retailer is suspected of containing other fibers than those specified on the label. From the retailer the name of the garment manufacturer is readily obtained. The inspector visits the place of business of the maker of the garment in question to ascertain where the cloth was made. He finds the garment maker bought the same kind of cloth from two mills, in both cases the cloth was bought as made of all new wool and was so branded. But it is impossible to determine from