,h/Zl/S 'VS\b
' ivo. 18 '
COITFIDENTIAL
LEMOPJU^IDUivI TO: SECTION HEADS December 18
1 9 ?> 5
SUBJECT: T7CRK I/ulTEEIALS ITO. 18
CONTENTS OE CODE HISTORIES
This document makes availalDle for confidential use nithin the
Division of Reviev/ the outline that is follo^ved in the preparation
of code histories. An examination of this outline will throvr light
upon the material useful in connection uith studies v;hich will be
found in each code histor^T-,
Although the outline contained herein ^.vas issued July 10, 1935
"by the Division of Hevien and although the Division of Review '.vas
from the first assigned the duty of reviewing and revising code
histories, it v.'as not until the latter half of August that full Juris-
diction of the preparation of code histories \7as vested in the
Division of Review, The code histories fall into tr/o major groups:
1, The histories of formally ajjproved codes. There are
in Central Records 757 approved codes and supplements.
In connection r/lth these, 814 separate histories are
"being prepared in order to cover adeo^uatelj'^ the situa-
tion in certain industries in v;hich there v/ere a numher
of chapters to the code. As of Deceraher 11, 1935, 374
of these code histories were completed, and 168 others
started,
2, The histories of codes not formally a.pproved hut concern*-
ing v;hich the records contain valuable material. There
are 259 such cases. As of December 11, 1935, 89 of these
were completed ajid 51 others started.
In addition to code histories, histories are being prepared of the
activities of particular divisions, boards, and other agencies of the
National Recovery Adj-ainistration,
Information concerning the histories that are available for examina-
tion may be secured from I.ir, R, C, Ayers, Commerce Building, Room 4309 —
Telephone Extension 645,
L. C. Marshall,
/ Director, Division of Review,
7888
\r.
{^
-•- -••
' ,• * V •:'•
TO: Division Administrators
¥ROU: Director, Division of Hevien
SIBJECT: Code Histories
The folloTTing is a revision of the memorand-um of the Code
Administration Director, dated l.iay 29, 1935, (Code Histories).
A doc-amented history of each code will "be prepared "by deputies
and their assistants, to he in accordance -jith the outline hereinafter set
forth. The or.tline is not to he digressed from except for such additional
discussion as may "be necessary or desirahle or in the treatment of a special
prohlem of the industry wherein it would he impossible to follow the outline,
A letter of transmittal should accompany the code history incor-
porated in the vol-'ome just after the tahle of contents. The letter of trans-
mittal should he prepared ''oy the deputy or other officer charged with the
responsihility of comT)iling and v;riting the history, addressed to the divi-
sion administrator, or other officer in charge, stating that the history
has heen ^rritten in accordance with the model outline, and that in his opin-
ion the submitted record adequately reflects the history of the c^de. The
letter should contain a signature line (lower left hand corner) for the
division administrator or other officer in charge, under the word "Approved, "
There should, he a short preface to each history which will indi-
cate the identity and. experience of the compilers thereof with the subject
matter, Obviouslj'- a history compiled by the deputy connected ^-^ith a code
and its problems from its very inception or for the greatest period of time
would carry the presumption of greater authority than one compiled by a
deputjr of lesser experience with the industry. The author and co-euthors,
if any, should certify to the authenticity of that part of the history
written by them by affixing their signature thereto.
Code histories should contain all information concerning the code,
therefore it v/ill be necessary for the author or authors thereof to put into
histories information i;hich is not a natter of record, but lies within the re-
collection and personal ]aiowledge of those connected with the code. Since
the code histories are for use within the administration and not for public
use all such information should be set forth in the histories in order that
they will completely embrace all unrecorded discussions and opinions. Fnere
no written record exists a notation to tliat effect should follow the state-
ment of the author giving the source of his knowledge of the facts, i.e.,
participation in conferences, etc.
If there were no written or verbal communications bearing on any
point mentioned in the outline the deputy should so state under the proper
heading so as to avoid inference that the subject was overlooked.
Reports will be obtained from adjninistration members
on such subjects as they are best fitted to discuss. These reports
are of the utmost importance and copies thereof should be included,
7888 1 ^ f'-y 35 g
Digitized by the Internet Archive
in 2011 with funding from
Boston Public Library
http://www.archive.org/details/worknnaterials18unit
-2-
as exhibits in the appendix of the code histories for the follor/ing
p-urposes:
1. General inf omia.tion.
2. Operation of code provisions.
3. I^inctionin^ of the administerinj^^- hody.
4. Adeq-u.acy of industry statistics.
5. Reconmer^dations.
Stress is laid on complete doc-uxient.^'.tion of t'-.ese hiL'tori3s
In no case -jill reference to source of material "by docmient and pa,^e "be
omitted*
Each volume \7ill conclude with a detailed and thorough alpha-
betical index. Volumes v;ill be bound in blue covers.
An original and five carbons will be made and bound, and when
completed will be for\;arded to the records section (Hoora 4321, Commerce
Building) for revicv/ and further disposition.
Reference to the code provisions and amendments thereto should
be made by article and section and by page number of code or amendment as
bound.
Administrative Orders should shoj order number, date and approv-
ing official.
Reference to reports of Government agencies other than ITRA should
give title and page, industry t-md. release number, and digest or e"tract of
im^Dortant material. If not too voluminous a copy should be included in the
appendix.
Reference to deputy's, general or other files should be so detailed
and specific that the material referred to may be readily located, including
date, name of sender and addressee of any communication referred to and where
possible a digest or extract of important material contained in the doc-oment
found in such files should appear in the history.
If the doc^ojnent is voluninous (such as transcript of hearing) refer
specifically to page and volume and ouote extracts if desirable or such por-
tions thereof as will convey the desired ideas adequately. In this way the gist
of such material is incorporated in the history and the docuiiient becomes a
collateral. If the document is brief and readily lends itself to copying with-
out too great a sacrifice of time and effort, it may be copied and made an
exliibit to be bound as an appendix. Fnen more than one document falls in such
a class the exhibits of course should be clearly identified and reference made
thereto at the proper place in the body of the history,
I. General Inf ormat ion
Reference should be made to the location of the primary material which is
the basis of research for the specific studies to be made.
7888
— o—
In this connect ioTx reference should be raade to the source. References
should he sufficiently specific to shov; where the sources of informal
tion are located such as Code Record Section, IT.R.A. , general, deputy's
files or name of staff function file,
1. Ref. Printed Code.
2. Ref. Yol. 1, II, III, Code Record Section. Article, section
and/ or page nu^nher.
3. Ref. Vo. A and B, Code Record Section.
4. Ref. Administrative Orders,
5. Ref. Deputy's files, H.R.A.
5. Ref. General files, N.R.A.
7. Ref, Research and Planning files, 11. R. A.
8. Ref. Legal Division and Compliance files.
9. Ref. Advisory Council Reports.
10, Ref. Advisoiy Boards files,
11, Ref. Government Agency reports,
12, Ref. Code Authority report in re Budgets.
13, Ref. Trade Association reports.
A. Definition of Industry
The lastest approved definitions should "be quoted in full from
the code. If the code has divisions and sub-divisions, such defini-
tions should also be included with references irrespective of whether
a supplement has not been approved. Consideration should also be
given to the generally and publicly accepted meaning of the respective
industry.
The evolution of the definition through the various drafts of
proposed codes with an explanation of the changes made as well as
references to tneir respective location should be included.
1. Ref, Proposed Code, Vol. A, Code Record Section.
2. Ref. Transcript, Vol. III.
3. Ref, Approved Code and Amendments, Article, Section and page.
1. Principal Products
A complete tabulation of industry products should be herein
enumerated such as those as may be found in:
1. Vol. Ill, A and B, Code Record Section.
2. Printed Code and Amendments (Article, section and page).
3. Department of Commerce Publications.
4. Classified lists of industries.
7888
- 4
2 . Products alpo iinaer Other Codes
In considering prodacts also ruider other codeG it ic, sii^'gested
that the statement be confineu as fc^r as possible to the bare list
of products under other coden (if none so state) material obtained
from sources such as:
1. Ref. Codes fjOArerning similar rctivities.
2. Hef. Administrative Orders, Interpretations and Classifications
3. Ref. Deputy's files.
4. Classified lists of industries.
B. Definition of Industry Member
A late and complete code definition of industry member (show-
ing additional inclusions or exclusions) should be herein incladed
with references such as:
1. Ref. Proposed Codes, Vol. A, B and III, Code Record Section.
2. Ref. Printed Code and Amendments, Article, Section and page .
1. Classes of Members
Members should be ranked together as possessing some
attribute in comr.on and for some conimon pumose, such as:
( a) J.Ianuf ac t loi- e r s
(b) Vfholesalers
(c) Producers
(d) Retailers
(e) Jobbers, etc. ,
and any subdivision thereof (natural or accepted) which
constitutes a separate and distinct group.
1. Ref, Proposed Codes, Vol. A, B and III, Code
Record Section.
2. Ref. Printed Code and Amendments, Article,
Section and page.
C . Statistics of the industry (salient only)
Under this section there should be furnished the most recent
salient industry statistics such as:
7888
- 5 -
(a) Total annual sales
(b) N-omoer of concerns
(c) Aggregate invested capital
(d) Aggregate production capacity
(e) Aggregate num'ber of employees
(f) Estimated net sales
(g) Latest available information as to the establishi.ents
in the industry
1. References to material within or outside IT.R.A.
References to the sources for this information sho^ald
"be set forth such as:
1. Recognizee commercial agencies
Examples: Dodge, Ihm £z Brads tree t, etc.
2. Department of Com.merce, Censu.s of Manufact-jTss .
o. Department of Commerce, Census of Distribution.
4. Research and Planning Bulletins and records.
5. Reports from sponsoring and interested groups,
including technical and statistical reports
prepared "by independent organisations, groups
and bureaus .
6. Claims by members of the industry. Volijme III -
Code Eacord Section.
7. Code fjles including Volume A and B mid Vol-ame II
of Code Record Section.
8. Correspondence file.
I I . History of Code Formulation
A. SiDOnsorin^: organizations.
1. Statements re true re-presentation. age and ob.iectives,
code meetings, et cetera.
The statements under this heading should support the
requirements of true representation as prescribed by KHA
policy setting forth in detail the age of the sponsoring
organizations, information relative to the meetings
held preceding the submission of the code and other avail-
able information in the official records. The histories
should indicate references such as:
1. Ref . Volume A and B, II and III of the Code
Record Section and Deputy^s and General
files.
7888
- b «
2* Off icers^ po^e ^coipiaittees, int er es ted _ £Toxups .
Tlie list should in elude:
(a) Officers
(1)) Code Cormnittees, and
(c) Other interested grcJopa
v^ith their
1, Affiliations, sponsoring t?ie proposed
codes, and
2, Should "be detailed v/ith appropriate
references, such as Volume A and B,
II and III of the Code Record Sec-
tion, and
3, Deputy's file, and
4, Oeneral Files.
^» From, sulpmission^ oJ'_.f^r-g!^- f^^P-^."*^.^'^Q'^^^, "Q. "';^"'-^]^^i^, he,aring.
All records pertaining to pre-hcaring conferences
and other ne^^otiations leadin^?; up to the first public
hearing should "be listed under this heading and should
he described by reference to the files and records
containing reports of these conferences and negotia-
tions, such as;
(a) Volumes A and B
(b) Deputy's File
(c) General Files
All topics of discussion at these conferences
sho'old be set forth and the decisions, if any, on
subject matters indicated herein,
C • Fubl 1 c^ H -ar ing s_ on cp d_e ,
•^ * Dates; ,^ ^riajpr^ p er spnnel ; ^ r esvJ ts .
The dates of all public hearings on the code
chronologically arranged should be indicated to-
gether v/ith the names, addresses and business af-
filiation of all important persons taking part
therein. The history sho'ola. show the major subjects
7888
- 7 -
discussed and vvhat was accomplished as a restilt of these
hearings. The reference slioiild he directed to Voliunes
II and III, A and B of the Code Record Section and ex-
hibits suhaiitted at the public hearin^iS presented in
support of the contention of the participating personnel.
In referring to records made at the public hearings for
use of subject matter contained in the p,time the formula-
tion of this portion of the history should be in accord-
ance v.'ith Office Instrcictions IIo. 5 of J-one 28, 1935.
The det^dls of the actual formulation of the code from
public hearing to the final approval should be set forth under
this section and sho\ild include a reference to all post hoaxing
conferences held together with a surma.ry of the subject matter
and results thereof. The information should be arranged as
follo\7s:
1 • ?r i ef^^sumnar^^ of ,_ po sir3CLpa?^ing„ conf erenc es .
Under suivmary of post-hearing conferences there
should be shov/n the action t^dcen in eacli case v/ith
reference to location of the documents including
Deputy's a,nd G-eneral Files, Vol-ames II, A and B
of the Code Ilecord Section,
2, Ap.'tiyi.t i.?.§.. il}-.,o'9Jt£i-,inin2_ approval ,
Considerable detail sho"jld be furnished in the
history for this paragraph and should include
(a) All avail cable data.
(b) Suira:iaries of post-hearing activity v;hich
took 2^1uce du.ring the final drafting
of the code.
(c) A description of the particu.lar code pro-
visions which may have been materially
changed from those discussed at the
public hearing,
(d) AnsY/ers and memoranda on disputed points
(including N.R.A. Advisory Board reports),
( e) Sufficient information to identify the
method and degree of indi^.stry assent
thereto,
(f) Supported by necessary reference, such as:
Vorcurne II and III, A and B, Deputy's
Files, exhibits and 3-eneral Files.
Assent - See Office Order 15, dated
August 5, 1933.
7888
- 8 -
3, Date of &-pprovsl.
P.ef. - Order approvin.^ Code - Code Record Section,
4 , Conditions in order of approva,!; industry reaction .
Each and every condition in the order of approval
should "be "briefly set forth. References - Order of
Approval - Code Record Section.
The industry reaction can "be "best determined "by
reference to the General ?iles containing, among other
information, those protests filed under Executive
Order 6205-B and other protests and reactions follow-
ing public approval of the Code as v/ell as the Ad-
ministration Member's report.
III. Code Administration
It is the intention to have a complete detailed history of
the Code Administration from its auproval until the date of the
Supreme Court decision of the Schecter case, and all conclusions
arrived at are to be s-u;|3ported by complete documentation, either
by reference or by coTJies of the essential dociJiiient,
A, General preliminar;/- discussion of the period of code adminis**
tration, covering general success of code, or lack of success,
chief difficulties encountered, extent of compliance or non-
compliance; to include a general orientation for the subse-
quent discussion.
When statements under this heading are made which cannot
be surpported by complete documentation but lie within the
recollection and personal knowledge of those administering the
Code, this fact should be noted in support of the statements
made. The preliminary discussion will include:
1. Difficulties of the Administration in launching
the Code Authority,
2. Developments of the problems incident thereto
during the full period of Code coverage of the
Industry.
When discussing the lack of apparent success of the Code,
or portion there. , if the facts or the reasons for these
difficulties are available, they should be set forth in
considerable detail, together with a reference to the location
7888
- 9 -
or documentatioii, or Gupporting data which ma7 "be referred
to, Corar)liance proolems should be se^rej';:ated "by classes,
that is -
1 . Wage s
2. Hours
3, Trade practice
4, Other typical provisions.
The data submitted should be supported ''oj the reports
of compliance offices, either in field or in Washington;
and where possible, statistics should be submitted, broken
down to set forth the results of adjudication of compli-
ance cases by voluntary agreements with Compliance Council,
Litigation Division and the Department of justice.
References should include:
1, Deputy's "Files.
2, General Files,
3, Administrative Orders,
4, Compliance Division Files,
5, Research and Planning Reports.
6, Advisory Board Reports,
7, Transcript on Hearings on Amendment,
8, Industrial Appeal Board Decisions.
9, Reports of Special Committees,
10, Reports of Administration Members.
B. Organi7.ation
1, The method of organization should be set forth in detail, with
appropriate references to the method of selection, and the
order recogniring the Code Authority, showing the order number,
and the date or dates of approval,
Ref. Code and Amendments, Article, Section, and page
number, Adi-ninistrative Orders,
Ref. General and Deputy's Files,
2, Personnel of Code Authority shoald include -
(a^ Names
(b) Addresses
(c) Company (Approximate size tliereof)
(d) Association or Group affiliation
(e) Geographical or other re->-iresentation
(f) A brief digest of the me'.:' tings held, and
(g) What was accomplished.
7888
-10'
3. Each and every change in the membership of Code A^ithority
(including the Adjnini strati on Mombor), should he set
forth in detail, if any, uith the reason therefor.
Ref. Adjnini rrbrative Orders.
4. Agencies of the Code Authority (including Divisional, Suh-
divisional, Regional and Special), should be commented upon
fully, and their activities, personnel and functioning
should be described in detail. These Agencies, for purposes
of this history, are to be segregated into -
(a) Local
(b) Compliance
(c) Statistical, and
(d) Other,
describing their
(a) Activities
(b) Personnel and functioning, and
(c) Citing the sources of reference.
Ref. Administrative Orders.
Rcf . Code and Amendments, Article, Section and page number.
Ref, Deputy's and General Files and Compliance Files.
(And any reports that may have been submitted by these
agencies),
5» Field organization, as distinct from local agencies,, if any,,
its set-u-Q, poners, duties and functioning .
1. Ref. Code and Amendiients, Article, Section and page
number,
2. Ref. Administrative Orders.
3. Ref, By-Laws.
a. Operation and Accomplishments
Ref, Code Authorities' Files and RoToorts.
6 , Disoission of oiperation of the code authority as an^ industry.
governing body, including- successes, failures, difficulties.,
and a general estimate of value^ also any evidence of
discrimination.
Under this section should be given a full description
7888
-11-
of the oporation of the Code Authority as an industrial
governing "body, including its
(a) Successes
("b) Pai lures
(c) Difficulties, and
(d) A general estimate of value of its "".vork
to the industry.
.Citing source of references,
1. Ref, Deputy's and G-eneral Files, and Compliance Files,
2. Ref. Administrative Orders.
3. Ref, Administration Member Reports,
C» iBudget^s_ancl^as_is_ of Assessment.
PuLl "budgetary history is essential and should include all
periods covered "by Irudgets, dates, order numbers, and the finan-
cial structure of the Code Authority for those periods. Dis-
tinction should he made between voluntary and mandatory assess-
ments, and separately commented upon,
•^ • Budgets as submitted- and approved.
Budgets as submitted and approved, should be detailed?
together with reference as to the location of the true
copies thereof:
1, Ref, Code and Amendments, Article, Section and
page number,
2, Ref. Administrative Orders.
3. Ref, Deputy's Files.
4. Ref. Code Authority Accounts Section
2, Termination of Paragraph 3 of Administrative Order X-36,
Termination of Paragraph 3 of Administrative Order X-36,
if any, should be referred to and pertinent orders digested,
1, Ref, Adjninistrative Orders,
2, Ref, Deputy's Piles,
3, Ref. Code Authority Accounts Section
3, Effect of Other Administra^tive Orders,
Administrative Orders relative to budgets and basis of
assessment, if they affected the particular Code, should
be mentioned, and the degree of effect thereof. In some
cases it may be advisable to set forth in considerable
detail the effect of these Orders,
'888 /
-12 & 13-
1. Rof. Deputy's files.
4 , Income from Laoels .
In thone industries whose Code provides for lalDels,
the history should recite the success or failure of labels
as a medium of income and the total ajnount of income
therefrom should "be sup^^lied witn appropriate reference.
If the Code did not provide for the use of la'bels, there
should he a statement to this effect.
1. Eef. Deputy's Files.
2. Ref, Code Authority Accounts Section.
3. Ref. Research and planning Division Files.
5 , Proportion of Assessments Collected.
The proportion of a.ssessraents shouldsshov/ the amo"an.ts
assessed and the c^jnounts collected, with percentages computed
on the "budgetary hases,
\
a. Discussion of Difficulties Involved, Certificates of Ilon-
Pgyment t protests and Actions Talcen. (Coordinate with
Compliance Division) .
It is important, under this headin^;^, to show the
success ov failure of the Industry to finance itself
through assessment, and particularly to show possible
lack of interest in later Code periods "by reporting
the falling off of collections as compared with earlier
periods of code coverage, and to recite, in addition
thereto, methods used by the Code Authority,
1. Ref, Deputy's Files.
2. Ref, Compliance Files.
3. Ref. G-eneral Files.
4. Ref. Code Authority Accourits Section,
6, Fin8n.cig.l operations of Code Authority in rela.tion to its
other operations .
The relationship of financial operations of the Code
Authority to its other operations, by '.7a,y of con^parison,
should be submitted under this section. This would particu-
larly apply to the history of those industries which presented
general Code Authority Administration difficulties, as well as
financial problems, due to lack of genuine support, either
from the beginning of the Code or a general falling off of
interest in its labor phases. References shoiild be m.ade to:
7888
- 14 -
1. ?.ef. Deputy's files.
2. Ref. Heses.rcli aiid. Flanninfr files.
3. Kef. Code Authority Accounts Section,
4. Ref. Code Authority files.
Administration of th? Code
1. Arn.endinents
The information supT:ilied here should incTiide a full dis-
cussion of ir.odif icatioiiP of the Code and should tie in, with
the subject matter furnished under the provision earlier dis-
cussed regarding problems of code administration, with the
idea of developing nnd rectifying the earlier TJi'oblems through
code amendment. This information should he completely docu-
mented by reference to the location of correspondence with
members in the Industry, Code Authority, and others, together
with a. reference to:
(a) Hearings
(b) Opportunities to be heard
(c) Post-hearing conierencr3s on amendments
Reference should be mc-de to:
1. Transcripts and Vol. II on amt-ndj'ients .
2. General and Deputy's files.
a. ibjffect on the industry
As fully as possible the history shoiild reflect
effect thesjs amendments and/or nodif ications had uron
the industry as a whole, both from the oioinion of thor-'«=-
administering the code as well as reference to corres-
pondence or o■^.her matter which may tend to elaborate upon
the effect of cncnges in the cod^e on the industry.
References such as:
Deputy's files.
Compliance files.
General files.
Administra,tive Orders.
Administration nembei's re'oorts
^ • Critical discussion of value of amendments, including
unaoproved £.,:i8ndnents .
From the point of code fidministration the history
should include a critical discussion of each amendment,
and if the ma.tter produced in the history is opinion
matter rather than information supported by diocuraents, the
author should so sta,te and his discussion of the value of
- 15 -
unap-proved amendments likevdse should "be so developed.
References should be noted to sources of information,
such as:
1, Special reports.
2. General and Deputj'-' s files.
2. Interpretations
a. The official interpretations of code provisions
should "be chi-onGlOf:;ically' arran^ced !>:/ epitomizing the
subject matter discussed therein, and settinjr; forth
the official order, together with the date and the
name of the person v;ho signed it. In each case the
official I'lEA interpretation should be set forth in full
in the appendix in the history. References should be
made to:
1. Administrative Orders.
2. General and Deputy's files.
3. Division Administrator's Orders.
b. The results of the interpretations reflected from
the inaustry point of viev should be stated and a dis-
cussion given in cases where the interpretation resulted
in conflict viith other industries later cod.ified: References
1. Administrative Orders.
2. General and De-outy's files.
3. Division Administrators' Orders.
c. A discussion of the value of approved interpretations
should be supplied, fully documented by reference to the
material supplied in support of the discussion. If the
matter supplied under this subsection consists largely of
opinion of the authors it should be so stated. References:
1. Adiiiinistrative Orders.
2. General and Deputy's files.
3. Division Administrators' Orders.
3, Exemption and stays
Exemptions are to be primarily grouped into classes,
with a complete summarization of each of the different
classes. That the summarization may be more illustrative,
it is essential to identify the most significant orders
in each class, giving a full discussion of their subject
matter, purpose and effect. In all cases of total exemp-
tions, (stays) they are to be separately indicated and dis-
cussed.
7883
- 16
1. Adraini strati Ye Orders.
2. General .aiid Deputy's files.
3. CoTnpliance files,
4. Research and Planning files,
5. Division Administrators' orders.
4 . Other administrative actions a.nd g.gcencies .
8.. Tra.de 'oractice complaints committees.
The names of "business affiliations, addresses,
and qualifications of the committee should he set
forth in detail, v/ith appropriate references such as:
1. Administrative Orders,
2. Deputy's and General files.
3. Division AoLiinistrators' Orders.
!• The organization, duties, a.ctivities, and
a "brief resume of the plan itself should "be
detailed with complete doc-amentation, and refer-
ences such as:
1. Administrative Orders.
2. Deputy's files,
3. Division Administrators' orders,
!>• La"bor Comnolaints Comjaittoes
The personnel of the committee, "business addresses,
ai'f illations and qiialif ications should "be included; if
none it should "be so stated, with references such as:
1, Administrative Orders,
2, Deputy's and General files.
3, Division Administrators' Orders,
1« The organization, duties, activities, a "brief
resume of the plan, and accomplishments, if any,
should "be detailed, with reference to:
1. Administrative Orders,
2. Deputy's files
3. Division Administrators' Orders,
7888
- 17 -
c. By-'laws
The lDy-lr;jB of the Code Authority, or any re^a-
lationr. or riiLes of procedure issued "by the Code Au-
thority, sho-old "be commented upon, and a,ny unusual
provisions set forth v/ith references such as:
1, j'Ldininist native Orders,
2, Deput;?"^ s an.d General files*
3, Division Administrators^ Orders,
1, Steps in ohtaining the approval of
"by-laws, recommendations of various advisers,
arnendjnent s made pursuajit thereto, approved
deite, -3Jid the general operation of the ru3.es
of procedure should "be ela"borated upon, with
references such as:
1, Administrative Orders,
2, Deputy's and General files,
3, Division Administrators' Orders,
d. Other
Any other peculiar administrative actions or agencies
including use of Trade Associations in administration of
code and effect of code on trade association, should
he specifically set forth in this section, wit>h complete
doc'omentation, and if none it should "be so indics.ted.
References such as:
1, Administrative Orders,
2, Deputy's and General files,
3, Division Adjninistrators' Orders,
5 . Other phases of code administration not covered a"bove .
Any other phases of code administration not heretofore
covered should be fully detailed and documented in this section,
with appro"oriate references such as:
1, Administrative Orders,
2, Deputy's and General files,
3, Division Administrators' Orders,
7888
- 18 -
IV. Qx^eraticn.^of .. code l^i'pyijr ionc..
A« p_efinitions
The operation of the definition propcsec' oy
the sponsors cand ibs relation to definitions con-
tained in code; for allied induntries sho-old be
elaborated upon fully, with /.iporopi'iate ref ereuccG
such as:
1. Proposed Code, Vol. Ill, approved
Co d e and Am endin en t r-. , Ai- 1 i cl e ,
Section and Page,
2. Administrative Orders,
5, Divi'-uon Administrative Orders.
li Any ouestioH of overlajpin;^ resulting' from
the definition which covered products or operations
of other indu.stries should be elaborated upon with
appropriate steps taken to adjust differences
arising; thereby and the author's recommendations
as to possible means of correction in the future.
Examples of steps taken, i.e.:
(a) Conferences.
(b) Pro-Qosed changes.
(c) Coordinating activities,
(d) Administrati'^^e suggestions,
( e) Clsissification orders.
If these recommendations are not substmitiated
by references but are based oh the opinion of the
author, it should so be stated. If tiiere is no over-
la-Qj^in^^;, this section should so state, Eeferences
should be given, such as:
1, Adifiini strati ve Orders.
<■•
Classifications,
3, Interpretations,
4 • All endm en t s .
5, General ;-.nd Deputy's Files.
oTDocial Board or Comiuittee Peioorts,
c
7, Division Administrators' Orders.
B, ?ag_cs
The basic v;age rates as contained in the code of
the industries in question should be set forth.
7838
- 19 -
Reference qv.cii as:
Code and Aiaendinents, Article, Section
and Pago.
1, The effect of the code v/a^e provisions upon
the industry v;age level as a whole; \ipon the
industry v;af^;e minima, and upon the avera-ere wage
rate. In this respect, additional statistics
may do necessary ^ander this heading to support
statements made showing the effect of changes
in T/age levels in the industry as a resiilt of
the adoption of the code, Furthei-more, complete
references should "be given to correspond with
all sources regarding the effect of wage pro-
visions, such as:
1, Vol. A, B, and III.
2» Code and Amendments,
3, Hearings.
4, Research and Planning Reports.
5, Exemptions.
3, Stays,
7, Depi-Lty's Pilos.
8, Government Agency reports.
9, Accepted Commercial reports (i.e.,
Dodge, and Dun and Bradrtreet),
10, Department of Commerce Census reports,
2, Industry compliance with code v;age rates should
"be elaborated upon, with appropriate references
such as :
1, Compliance Division Piles,
2, De];3uty*s and G-enero.l Piles.
3, Research and Planning reports.
4, Labor Advisory Board re-oorts,
3, SLcilled and semi-skilled wages rates should be
stated in detail and it should be further stated
whether or not s\"ich skilled v/age rates were or
were not arrived at through collective bargain-
ing. As an example, there may have been developed
in the particular industry considerable history
preceding the adoption of the code relative to
the establisiiment of skilled wage rates in the
industry which should be tied in as "oreceding
7888
•20 ~
history to the adoption of the code vfaj^e rates,
with appropriate references such as:
1. Compliance Division Files,
2. Deputy's a.nd General i'^ilea.
3. Eesearch and Planning reports.
4. Labor Advisor^'' Board reports.
4. Any code provision requiring the adjustment of
wages upward should be elaborated upon under this
section. References such as:
1. Corapliance Division Files.
2. Deputy's and General Files,
3. Research and Planning ReT)ortr;.
4. Labor Advisory Board Reports.
5. Code and Airiendraent s , Article, Section
and Page.
5, Any mal-adjustment v/ith other industrier. should
be treated under this section. This incliides
business conflict \7ith other codes covering
similar operations wherein the codes contain
less favorable wage rates than in the code
under discussion.
6, A brief resume of the posting of labor provisions
in so far as they affect wages, and their ob-
servance by industry members, should be detailed,
7. Comment is to be i:ade whether 11, R. A. insignia was
displayed, and to what extent, as evidence of
the industry's compliance v;itii the wage provisions
of the code.
C, Eours.
1. The general effect of hours provisions of the
code on tha industry as a whole should, be noted.
Under this heading there should be set forth com-
plete information regarding the effect of
shortening hours upon emplo;;.Tii3nt, with appropriate
references such as:
1. Vol. A, S, and III.
2. Code and Amendments, Article, Section
and Page.
3. Hearings.
4. Research and Planning reports.
5. Exemptions.
6. Stays.
7. Deputy's Files.
8. Government Agency reports.
738c
- -21
2, Unusual provisions such as tolerances, peai-:-
period, and various differantials, should be
treated separately, supported fully 'by reference
to correspondence and/or infoi^iation contained
in official records, and in ca.^es of differentials
the natter should be ei-diaustively treated. PeaJc-
period provisions should "be tied in i7ith requests
for exemptions if such iDrovisions in the code
were of insufficient length to conply with in-
dustry prohlenis due to seasonal pcalj:s. References
such as;
1. Compliance Division Tiles.
2. Deputy's and General Files.
3. Research and Plarjiin^^ reports,
4. Lahor Advicor;r Board reports,
3, A recitation of industry compliance witn your
provisions should he set forth and v/nore jDOSsihle
statistics should he pi'ovided, Purtheniore,
compli^jice sources and labor "Ujiion information
supplied T-.here available, uith appropriate references,
such as:
1. Compliance Division Files.
2. Deputy's ano. General Piles.
3. Resea,rch and Planning reports.
4. Labor Advisory Board reports.
4, Any mal-adjustnent uitb other codes coverin^^
similar opera.tions v^ierein tlie codes therefor
contain less favorable hour provisions than in
the code luider discussion. References such as:
1. Compliance Division Files.
2. Deputy's and General Files.
3. Research and Planning reports.
4. Labor Advisory Board reports.
5, A brief resuiiie of the posting of labor provisions
ir so f£ir a,s they affect hours, and their ob-
servance b;/ industry mcvmbers, should be detailed,
6, Comment is to be made ivhether N.R.A. insignia was
displayed, and to what extent, as evidence of the
industry's compliance with the hour previsions
of the code.
7C88
~ ;:2 -
1, Attention should "be given to the reduction in
cliild lalDor with conplete information as to the
conditions existin-^ "before the adoption of the
code, v;ith full references, such as:
1. Vol. A, 3, and III,
2, Code ojid Amendnents, Article, Section
and Pai^e*
5, Hearings.
4, Research and Planning; reports.
5^ Exempt ions.
'•?. Stays.
?• Deputy's Piles.
G, Government Agency reoorts.
2* The extent of homo work activities in the industry
Lefore the ado-ption of the code and the effect
of the limitations placed thereon "by code pro-
visions should "be detailed with ftill references
scich as :
1. Administrative Orders.
?, Eeoorts of Special ConuTiission.
3« Research and Planning reports.
4. Reports of the various Advisory Board.
5. Code Authority reports.
6. Greneral and 'Dep-o-ty's Files.
3# Code provisions, for handicaro-j^ed workers should
"be included ana detailed stctem.ent made as to
the general effect of these provisions, as well
as Scecutive Order, upon this class of \/orkers.
References, such as:
1. Code and Amendments, Article, Sf^ction
and Page.
2. Compliance Division Piles.
3. Deputy *s and General Piles.
4. Research and Planning reports.
5. La'bor Advisory Soard re-oorts.
4, Apprentice and learner provisions should "be de-
tailed and the effect of these provisions upon
employment of this type of workers in the industry,
and if there appear to have "been efforts made "by
employers to ejcploit this tj^npe of worker through
7383
- 23 -
the use cf these provisionc in the code, full
ejqplanatioii should be set i'orth, together \7ith
the ste]?s taken "by the Admnistration to alleviate
the prolyl cr.i. Refer once should oe made to the
location of correspondence and/or records re-
sulting from any such action. References such
1. Code and Amendments, Article, Section
and Page,
2. Compliance Division Files,
5. Deputy's and General Files.
4. Research and Planning reports.
5, Lahor Advisory Board reports.
5, Statement as to the operation of all other lalor
provisions incorporated, in tne code should "be
elaborated upon, v;ith references such as:
1, Vol. A, B, and III.
2, Code and Amendments, Article, Section
and Page.
3, Hearings.
4t, Research and Planning reports.
5, Exemptions.
6, Stays.
7, Deputy's Files.
8, G-overnraent Agency reports.
E, Adiiii_ni s tr at i y e^.p^'pyl si ong •
1, The nature and extent of the investigation of
records as set forth in the code should "be shovm
cUid the history should include whether or not the
section v;as the model code provision. References such as
1. Code and Amendments, Article, Section
and Page,
2. Administrative Orders.
3. Deputy's and General Piles.
4. Compliance Division Files.
2. Fnether or not collection of statistics v/as
delegated i:o the confidential agency, or some
agency of the Code Authority, or some govern-
raental agency, and the nature of the provision in
7888
the Code (whether model fom or othonvise), as
well as the success or failii-re of the operation of
the section should be set forth in detail v:ith
references such as,
1. Code and Amencirnents, Article, Section
and Page.
2» Administrative Orders.
3 . Deputy • s aiid Gene ral Fi 1 e s «
4. Compliajice Division Files.
Z, If the Code contained the model lic^aidated
damage provision it sho-old he so stated, with
appropriate references. If not, it should he
stated whether or not there wa-s any provision
for liquidated damage and, if so, the provision
should oe briefly digested \;it!i appropriate
references such as:
1. Code and Amendments, Article, Section
and Page,
2. Administrative Orders.
0. Depr.ty's and General Files.
4. Conpliance Division Files.
4, Any other adriinistrative provisions should be
treated fully v/ith detailed references, such as:
1. Code and Ar-iendments, Article, Section
and Page.
2. Administra.tive Orders.
3. Deputy;-' s and C-eneral Files.
4. Compliance Division Files.
F. Price and Accoun.tin-^; Provisions,
All pertinent features of the Code provisions re-
garding price control and accounting should be
detailed with a full discussion of t-ie:
1. Operation of these provisions, and,
2. Their hnowji effect on all classes
of the industry membership.
As these tyr^cs of Code provisions resulted in
7888
— ^F-.
conBideralDle controverc^, noii-conpliajice, and
other -Ti'o'talens a full lecitatioii of such pro'bleins,
if the-j arcose, should 'he elaoorated upon in the
his tor--. It is thought advisable to give some
iiistoric oack^^ronnd of problems confronting the
industry" previous to the adoption of these pro-
visions, with jjarticular reference to price
cutting and extreme competitive conditions
therein. Full reference shorJLd "be given to
sources of inforr^ation, such as:
1. Code and Aiaend::ients.
2 . Deiiut 2" ' s and G-ene ral Files.
3. Adrainistrative Orders,
4. Research and Plannin;,'?^ reports.
5. Borrds and Connitteo reports.
Price ffiling.
Code provisions providing for price filing
should be set forth in detail s.s to the conditions
making price filin.^;; provisions advisaole, and the
history should recite the results of price filing
provisions if they existed, together "Tith the
problems arising incident tlioreto. References
s^ich as:
1. Code and Ai'iendiuents, Article, Section
and Pc\ge.
2. Deputy's and G-ene ral Piles.
3. Afcinistrative Orders.
4. Research and Planning reports.
5. Boards and Committee reports.
TTaiting Periods.
Waiting periods, if provided in price filing
provisions should be discussed in detail, together
Yilth the degree of complitmce and the s^iccess or
failure of such provisions. A statement should
also be included a.s to v/hether or not the waiting
IToriod was stayed in the order of approval as
req_uired oy adiainistrative polic}'", with references
such as:
7838
1. Ccdo ond Amenair.ent s, Article, Section
and pp^e.
2, D^^puty*"^ and G-emrsl rii-f^f^,
3, Admi;:.istrativo Orciers.
4. ReyearcL and planning x-f^portij.
Boards ond. Gomrittee reports.
c
*- • Smer.geno;/ Px-ic? Bases .
In tLose codec in which there were provisions
controZ-ling- prices, and per;nitting the declaration
of an emergGncy the effect bhereof and action
taken thereunder should he set forth in detail
with references such as:
1. Code and Aiaendiaent s, .A'ticie, Section
and Pae;e.
2. Deputy's a^id G-eneral Jlles.
3. Administrative Orders,
4. Research and Planning reports.
5. Boards and Committee reports,
3, Accounting Systems or Copt _ Systems.
Wnere accounting systems or cost systens
were provided for a statement as to whether they
Kero st?u'-dard or model or other\/ise should oe
made. Their success or fail. are in accoirrp dishing
the pui^poBCs causin.-c their adoption should he
set forth in detr?il. P.eferences such as:
1. Code and Ajiiendi.ients, .Article, Section
and Page.
2. Deputy* s and G-eK.eral Piles,
3. Adroixiistrative Orders.
4. He sear en and Planning r':^ports.
5. Boards and Com: dt tee re-_)Orts.
4. Administrative Price Polic;^.
Per those industries v/aich did not ado-ot
the provisions suggested pjid accepted as the
policy of the Adnixii strati on (Office l.Iercoranda
of 1/29/34, 2/3/34 and #228 of G/7/34) respecting:
7388
" ?r( "
(a) Price filing.
(b) ii]rner<;;enc7 prices,
( G ) A'': c OTint ing , or,
(■l) Cust systems,
the reasons therefor should do v^iven, with
pr.rticala.r re.^'ureuco to their:
^ . » AcTot t a"b i 1 i 1 7 , and. ,
3. De:.irabilit7
in the industry ^anaer discussion.
i'or those industries which did adopt any of such
provisions, their accepta"bility and effect in
the industiy should he elaborated upon.
5, Clas s if i cat ion of Cus t one r s .
Provisions relative to classification of
customers should he set forth, together with
pji outline of the results of such pro-7i:;ions,
and their effect on industi'y proDlems. In this
respect the code provision in relation to the
policy x^re scribed hy office memorandum 267 should
de disciissed in detail. References such as: _^
1, Code and Amendiiients, Article, Section
a.nd Page • -> ■•
2, Deputy's and General ITiles,
3, Administrative Orders.
4, Research and Plajining reports,
5, Boards and Committee reports.
S • Price Differentials
Price differential provisions should he de-
tailed to provide a hackground for the a.doption
of price differentials, together v:ith the success
or failure of such provisions in the operation
of tlie Code. References such as:
1« Code £ijid Aiacnd-v.ents, Article, Section
and Page.
'3a Deputy's and General j'iles,
5, Administrative Orders.
4, Research and Planning reports.
5. Boards and Committee reports.
7888
-- 28 -
a. Stop-loss Provisions..
provisions providing for stop-loss should
"be digested T,/itii f-cQl reference to tne loca-
tion of rnf^terial supplied thereunder.
References such as!
1, Code £jid AmendjnentG, Article, Section
and Page,
2, Deputy's and General Files,
3, Administrative Orders,
4, Research and Planning Reports.
5, Borrdsand Committee Reports,
'^ • ?er.as of pa.;^.r''OPnt «
1, Code and Ainendnents, a'lrticle, Section
o.nd Pa.'^fe ,
2. Deputy's and G-eneral Files,
G. Administrative Orders.
4. Research rnd Planning Reports.
5. Boards and Ccmnittee Reports,
8, Cooperatives,
Code provisions relative to cooperative
organizations should he included, together with
their relationship to conditions set forth in
Executive Orders 6355 of 10/23/33 and 6506A of
2/17/34 regarding coopero.tives. pLeferences- such as!
1, Code and Anendraents, Article, Section
and Page .
2, Deputy's and General Files,
3, Adninistrative Orders,
4, Research and Planning reports.
5, Boards and Committee reports,
G-. iTrade Practices.
R-eferences:
1, Code and Anendaents, Article, Section
and Page ,
2. Administrative Orders.
5, Deputy's and General Files,
4, Compliance Division Files,
5, Advisorjr Board and Special Committee
reports.
6, Federal 'irade Commission Orders and
Court Decisions,
7888
1. Glass. A Trade Practice s«
The follc'.ving are examples of Class A Trade Practices:
1, Use of false or raisleading advertising,
2, Kisl)randin{? of faT3rics and other corr.iodities.
3, Bribing "bi^yers or other eip.ployees of
4-» Procuring the business or trr'd.e secrets of
competitors,
5, Inducing;; erployees of competitors to violate
their contracts,
6, Making false and disparaging statements,
7, T7ide spread threats to the trade of suits for
pa.tent infringement,
8, Passing off goods or articles for well and
favorably kno\7n products,
9, Selling rebuilt, secondhand, renovated, or
old products, as and for new,
10, Paying excessive prices for supplies for the
purpose of elimina.ting competition,
11, Using conce82ed subsidiaries, to secure
competitive business othenvise unavailable,
12, Using merchaiidising schemes based on a lot
or chance,
13, Cooiperative schemes and prices for compelling
wholesalers ?^iiq. retailers to mainta.in re-
sale prices,
14, Combinations or agreements of competitors to
enhance prices,
15, Various schemes to create the impression « • »
customer , , , is being offered an opportunity
to m?^e a purchase under unus-u^illy favorable
conditions.
7888
-30-
(a) Seller's us"j.al price is ir.lscly
represented,
("b) "i'rce" goods.
(c) Liisleadiii^ trade names ,
(d) Pretended exaggerated retail prices,
16, Siibsidikiing pii"blic officials or employees,
17, Imitating or using standard containers
customarily associated in the mind of tlie
general purchasin,']; pulilic V7ith stand;jrd
weights or quantities,
18, Concealing "business identity.
19, Misrepresenting in various ways the advantages
... of dealing v/ith the seller,
(a) Seller's alleged advantages of location
or si?!e,
("b) }?also claims of being the authorized
distrilRitor of some concern.
(c) Alleged indorsement of the concern or
product "by the Government or "by
nationally Icnown businesses,
(d) ITalse claim by a dealer in domestic
products of being an importer,
(e) Being manufacturers' representative,
(f) Representing falsely that the seller
is a wholesale dealer,
20, Use , , , which result or are calculated to
result in the observance of uniform prices
or practices for the products dealt in.
21, Securing business through undertakings not
carried out . , , through dishonest and
oppressive devices calculated to entrap and
coerce the customer.
7888
-31-
(a) Securing 'by deceit prospective
customer's signature,
(b) Securing business by advertising a
"free trial."
22, Criving products misleading names • .
(a) Implying falsely that , , , prodacts
. . , made for the Government .
(b) They are composed , • , of ingredients
. • . contained only to a limited ex-
tent or not at a,ll,
(c) Made in or came from some locality
famous •
(d) Made by some well and favorably known
process.
(e) Have been inspected, passed, or approved.
(f ) Made under conditions or circumstances
considered of importance by a suIk*
stantial part of the general pur-
chasing public.
23, Selling below cost,
24, Dealing unfairly and dishonestly with foreign
purchasers,
25, Coercing and enforcing uneconomic . . •
monopolistic reciprocal dealing,
26, falsely representing that a moving picture is
a pictorial, and any other fully established
by adjudication or J.T.G. orders.
References such as:
1, Code and Amendments, Article, Section
and Page,
2, Administrative Orders,
3, Deputy's and General Files.
4, Compliance Division I'iles,
5, Advisory Board and Special Committee Reports.
6, jj'ederal Trade Com.mission Orders and Court
Decisions,
7888
- 32 -
a. A complete discussion of tlieir efficacy,
and their effect on the various classes
of members in the industry as well as
actions taken imder and pursuant to each
such unfair practice. Reference s:
1. Code and Amendments, Article, Section
and Page.
2. Administrative Orders.
3. Deputy's and G-eneral Piles.
4. Compliance Division Files.
5. Advisory Board and Special Committee
Reports.
6. Federal Trade Commission Orders and
Court Decisions,
2. Class B. Trade Practices should include all others
not included under Class A.
h. A complete discussion of their efficacy,
and their effect on the various classes
of members in the industry as v/ell as
actions taken under and pursuant to each
such unfair practice. References:
1. Code and Amendments, Article, Section
and Page.
2. Ad-mini strative Orders.
3. Deputy's and General Piles.
4. Compliance Division Files.
5. Advisory Board and Special Committee
Reports.
6. Federal Trade Commission Orders and
Court Decisions.
H. Other provisions.
Any and all other provisions not heretofore dis-
cussed should be here elaborated upon. References such as:
1. Code and Amendments, Article, Section
and Page.
2. Administrative Orders.
3. Deputy's and 0-eneral Piles.
4. Compliance Division Files.
5. Advisory Board and Special Committee Reports,
6. Federal Trade Commission Orders and Court
Decisions.
7888.
-33-
1, If the so-called constitution ''hed^jc" clause (as
was included in the Small Avus and Amunition
Code and the Automotive Parts and Equipment
Supplements); is included in the code the reasons
therefor and the effect thereof shoiild "be elahorated
upon. pLeferences su.ch as:
1» Code and Amendments, Article, Section
and Page,
2, Administrative Orders*
3, Deputy's and General Files*
4, Compliance Division Viles,
5, Advisory Board and Special Committee
Reports^
6, Federal Trade Commission Orders and
Co'ort Decisions,
V « Recommendat ions , \
Under this heading the authors should make use of all
available information "based upon documented evidence and/or
personal Imowledge relative to the Code as a whole from
hoth industry and IGIA point of viev;.
A» Undesirahlc or Unenforceahle provisions.
This matter should include the undesirahle or
unenforceaole provisions in detail mth full reference
to the Code and Article, together with information as
to the reasons why such provisions appeared to he un-
desirable or unenforceable, and shotild refer in
detail in each case to whether or not the statements
are of mere knowledge, from experience, or based upon
information contained in records and documents avail-
able as annotated references and should include
general info rsat ion,
B , Compliance with code.
It is suggested that ma,tters relative to complianoe
with the Code should be thoroughly discussed, and if
possible, statistics and other information on com-
pliance matters should be set forth in the appendix
in considerable detail,
C, Limit a,t ions on Production, Machinery, Sliifts, et cetera.
In those Industries' Codes of which provide for
7888
~?;4-
imitation
on:
(1)
Production.
(2)
Macliinerj/',
(3)
Shifts, et cetera«
It is imporativG tlia^t these unusual steps in
industrial development "be thorou^ly treated in the
Code history, v/ith full references, such as:
1.
2.
3.
6.
7.
8.
9.
10,.
11.
Printed Code,
Vol, I, II, III, Code Record Section,
Vol, A and S, Code Record Section,
Administrative Orders.
Deputy »s files, IIHA.
General files, :MRA.
Research and Planning files, IIPlA*
Legal Division and Compliance files.
Advisory Council Reports,
Advisory Council Files,
Government Agency Reports,
Code Authority report in re Budget s»
D» Possihle Code Consolidations,
Discuss all possihle consolidations to the end
that the number of codes may "be reduced to a mininujn,
VI, Personnel
In listing the menl>ers of the personnel connected vjith
the code from date of its submittal to the present time,
it is suggested that the following form, if possi"ble,
should he adopted:
1, Division Administrators -
2, Deputies -
3, Assistant Deputies -
4, Aides -
5, Legal ~
6, Laoor -
7, Consumers Advisory Board -
8, Research and Planning Div, •■
9, Industrial Advisory Board -
10, Administration Memoers -
11, Miscellaneous -
Name and date comiected nith Code.
7888
- 35 -
VII. Signature.
Code histories \7ill "be used for special studies,
therefore, it is highly important that the identity and
e:vC'erience of the compilers he shown. The author and
co-authors, if any, v/ill certify to that portion v/ritten
hy them "by affixing their signature thereto.
VIII. Inde;
Upon the completion of the history, it should he
thoroughly and alphabetically indexed v/ith reference
to the location "by page of the important heading and
suh-headings, and a reference made to the appendix
v/ith page loca.tion of the contents thereof*
General Comment; The carbon copy of the original
should be an exact duplicate, and should contain a com-
plete appendix and copies of inserts such as Code Imend-
ments and other official docuiiients, and completely in-
dexed in the same manner as the original, in order that
a v/orking carbon copy may be used for such research
purposes as may be subsequently decided upon.
7888-#