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,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, 



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-•- -•• 



' ,• * 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, 

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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. 



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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. 



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2 . Products alpo iinaer Other Code s 

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 onl y) 

Under this section there should be furnished the most recent 
salient industry statistics such as: 



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(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. Referenc es to materi al 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^: organization s. 

1. Statements re true re-presentation. age a nd 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. 



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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, sulpmiss ion ^ oJ'_.f^r-g!^- f^^P-^."*^.^'^Q'^^^, "Q. "';^"'-^]^^i ^ , h e,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 



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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. 



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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 prel i minar;/- 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 



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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. 



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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 agenc ies,, if any,, 
its set-u-Q, poners, d u ties and functioning . 

1. Ref. Code and Amendiients, Article, Section and page 

number, 

2. Ref. Administrative Orders. 

3. Ref, By-Laws. 

a. Operation and A cco mplishments 

Ref, Code Authorities' Files and RoToorts. 

6 , Disoissio n of oiperation of the cod e authority as an^ industr y. 
governing body, including- successes, failures, difficulti es., 
and a general estimate of value^ also any evidence of 
discrimination . 

Under this section should be given a full description 



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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 submitt e d- 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, 



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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 
oth er 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: 



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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 v alue of amendments, including 
unaoproved £.,:i8ndnen ts . 

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. 

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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. B y-'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. Ot her 

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, Ac counting Systems o r 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. Admi nist rative Pr ice P o lic;^ . 

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 D i fferentials 

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 Provisi ons.. 

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''OPn t « 

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-. iT rade 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 co de. 

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, L imit a,t ions on Production, Machine r y, 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. 












































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- 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 Commen t; 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. 



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