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(1) It is postulated on a legislative finding of facts which, insofar as the wool textile industry is concerned, are flatly erroneous, both in their statement of evils which are alleged to exist, and in the effect on interstate commerce which is alleged to result from those evils.

(2) It proposes to correct those assumed evils by regulations, prohibitions, and economic boycotts which, if put into effect, would, beyond doubt, impede interstate commerce in textile products and defeat the end sought to be accomplished.

(3) Viewed as a regulation of the detailed operations of the business, it imposes burdens so heavy that they would necessarily result in injury to employers and employees alike, and it places in the hands of a Government body broad powers which are unjustified by conditions in the industry for which I speak and which are capable of ruinous abuse.

The first objection is vital since it is the false assumptions contained in the legislative findings of fact which are presumably thought to justify the drastic Government control over private industry imposed by the bill itself.

The first false assumption is as to the existence of specific abuses at the present time. Section 2 (a) finds as a fact the existence ofwages below a decent standard

excessive hours, child labor, overburdensome work assignments, other unhealthy and demoralizing conditions of work

and excess production Speaking for the wool textile industry, I wish to point out that the facts belie these statements, which I shall refer to briefly in the order stated in section 2 (a).

First, wages. I will ask Mr. Humphreys to give you an exhibit to which I shall refer.

EXHIBIT A

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Average hourly earnings of factory employees on pay rolls of wool textile industry

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Source: January 1929-August 1933 read from chart on p. 42 in Hours, Wages, and Employment Under the Codes, by N. R. A. September 1933 and thereafter association reports.

Exhibit A, hereto attached, gives the average hourly wages paid in the wool textile industry by months from the period January 1929 to November 1935, the last month for which we have figures. This tabulation shows that wages have not been decreased since the termination of the industry's code and that the average wage is considerably above the minimum of $14 prescribed by the code. The present average hourly wage of 47.7 cents compares favorably with the peak of 49 cents reached in the so-called boom year of 1929.

I think you gentlemen possibly will have some questions on this exhibit a little later.

Exhibit B, hereto attached, shows a graph of the employment index of the wool textile industry contrasted with the index for all industries. This graph shows the extent to which employment in the wool textile industry has improved and shows that the index is now 11 percent higher than the average for 1929. The industry during the past year distributed in wages a total 40 percent greater than in 1934. The graph likewise illustrates the unfortunate effect of the unjustified and abortive strike in September 1934.

That is the very substantial dip you will notice for that year.

ExHIBIT B

STATISTICS OF WOOL MANUFACTURE DECEMBER 1935

The chart on opposite page presents graphically the pay roll and employment indexes for wool textiles and for all manufactures for the past 3 years by months and for 3 more years by averages for the year.

The following table sets forth the indexes of employment and pay rolls, the average hours worked, average hourly earnings, average weekly earnings (actual, full time, and adjusted) and the purchasing power of the dollar as published by the National Industrial Conference Board.

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Second, as to excessive hours.---The wool textile industry cannot be charged with working its employees excessive hours. The 40-hour week as established by the code and continued by the approved rules of business procedure has been observed by 95 percent of the industry. That is a conservative statement. Hours of work have not been increased except in a very few instances and then largely due to emergency conditions which were of a temporary nature.

I might say at this point that during the operation of the code the administrator in Washington permitted a deviation in extraordinary circumstances from the hours and other provisions. We have contined the same practice by having a business conduct committee to pass upon those same applications.

Attached hereto is also a copy of the rules of business procedure adopted by the industry.

Exhibit C NATIONAL ASSOCIATION OF WOOL MANUFACTURERS-RULES OF BUSINESS PROCEDURE FOR THE WOOL TEXTILE INDUSTRY To Members of the Wool Textile Industry:

Subject: Rules of business procedure for the wool textile industry. The new suggested rules of business procedure for the wool textile industry which retain most of the features of the old code of fair competition adopted 'inder the N. I. R. A. are enclosed for your consideration.

COMPARATIVE TRENDS IN FACTORY EMPLOYMENT AND PAYROLLS

(1929 Monthly Averede - 100) EMPLOYMENT INDEXES

PAYROLL INDEXES

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I think you gentlemen possibly will have some questions on this exhibit a little later.

Exhibit B, hereto attached, shows a graph of the employment index of the wool textile industry contrasted with the index for all industries. This graph shows the extent to which employment in the wool textile industry has improved and shows that the index is now 11 percent higher than the average for 1929. The industry during the past year distributed in wages a total 40 percent greater than in 1934. The graph likewise illustrates the unfortunate effect of the unjustified and abortive strike in September 1934.

That is the very substantial dip you will notice for that year.

Exhibit B

STATISTICS OF WOOL MANUFACTURE DECEMBER 1935

The chart on opposite page presents graphically the pay roll and employment indexes for wool textiles and for all manufactures for the past 3 years by months and for 3 more years by averages for the year.

The following table sets forth the indexes of employment and pay rolls, the average hours worked, average hourly earnings, average weekly earnings (actual, full time, and adjusted) and the purchasing power of the dollar as published by the National Industrial Conference Board.

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Second, as to excessive hours. The wool textile industry cannot be charged with working its employees excessive hours. The 40-hour week as established by the code and continued by the approved rules of business procedure has been observed by 95 percent of the industry. That is a conservative statement. Hours of work have not been increased except in a very few instances and then largely due to emergency conditions which were of a temporary nature.

I might say at this point that during the operation of the code the administrator in Washington permitted a deviation in extraordinary circumstances from the hours and other provisions. We have contined the same practice by having a business conduct committee to pass upon those same applications.

Attached hereto is also a copy of the rules of business prom adopted by the industry.

Ехнівіт с

NATIONAL ASSOCIATION OF WOOL MANUFACTURI

OF BUSINESS PROCEDURE FOR THE WOOL TEXTILE
To Members of the Wool Textile Industry:

Subject: Rules of business procedure for the wool textile indus The new suggested rules of business procedure for the wool tex which retain most of the features of the old code of fair competit under the N. I. R. A. are enclosed for your consideration.

COMPARATIVE TRENDS IN FACTORY EMPLOYMENT AND PAYROLLS

(1929 Moatbly Average - 100) EMPLOYMENT INDEXES

PAYROLL INDEXES

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