-319--

 EX'T- IT -
 Pa'rt .


 December 19, 193/'


Mr. Leigh E. Ore
An-.istant Denuty Administrator
Commerce Building
Washington, D. C.

Dear :Tr. Ore:

 'e are in receipt of a cOnT):' of the :nemorndutm submitte b*,
;'-r. ?-.osenz'"eig covering our nl;.n for the control of home"'ork., re
have note carefully i.Ir. Rosenz-'ei 's objections to the -lan, "nd
his renuest for further information on some of the noints covered"
in the nlon.

 IHand-beading and crochet-beding '-e the only home"-ork onera-
tions permitted by our coce. Therc. are ;-boat 3m,0 home"'or'ers '-ho
Perform this particular '-orc. Of this number, our industry emnlo.'s
about 240) worke-rs. T etze -orkerr Pre scr. ttfrF:d throughout six
states and about 200 coniunities. Hitnc-.e-tding7 lnd crochet-beading
are skilled operations, ;'ndC c-mn only. be performed after more than
a year rractice, most of the good "orl:ers are those "ho learned to
do this work in their native countries and ,',ho never did this -'ork
other than in their o-n homes.

 At the hearing of the Pleating, Stitching and 3onnaz nnd Hand
Embroidery Code Authority held in 'hshington -n November 20, niembers
of that industry gave evidence that continuous advertising for hand
and crochet beaders to work in the factory resulted in only a few
workers annlying. To be exact, the number "'a-s str,-ted as sixteen.
This has been the same e:-nerience of members of our industry "ho
also advertised for crochet bender? to ,ork in the factory. Very
few such workers annlied, the reason being that the wor.:ers are so
widely scattered, that no factory whereever establishe,-l -ould be
convenient to any considerable number of "-orkcrs.

 The average time for the crochet beading of a, bag takes from
one to t-o hours for one b-g, ro that nn avrrR'e worker on crochet
beaded bags produces in an eicht hour l y -.bout four to six bags a
day. The production renuireci for an aver, -e manufacturer is at
least sixty dozen a day an', in the Peason about 120 do.:en : day,
so that a manufacturer would have to enoloy 120 workers on crochet
beading alone to produce 720 bags P day, and in the season ?40
workers to n-oroduce 14-40 bags. besides, he must emnlov other workers
who do cutting operating and finishing on the bags. There is not
a manufacturer of beaded bags who can establish a factoryv in any
locality in the United States "-.,d nbt; in 240 experienced crochet bead
workers on handbags who a-e living within n any convenient distance,
willing to oerfor!n the work in the factory. The production of cro-
chet beaded bags is so slo'" that overhear1 costs would be nrohibi-
tive if the work was nerformed in the factory capable of housing a
9811