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T'ftjFichHWPs College











of the

Women’s Bureau, No. 146


For sale by the Superintendent of Documents, Washington, D. C.

Price 10 cents


Letter of transmittal
The woman buyer’s stake in the apparel industry_______________________
A program of industrial stabilization
Support of the woman buyer in the program of industrial stabilization. __
The Consumers’ Protection Label
The influence of label patronage on other apparel industries________
The future policy of women in apparel buying__________________________
Fashion effects upon conditions in the coat and suit and dress industries. _
The jobber-contractor system of manufacture______________________
Specific conditions in the New York metropolitan area_____________
Seasonal difficulties of the coat and suit and dress industries____________
New methods of control in the coat and suit industry___________________
Control of jobber-contractor relationships
Scientific attempts at wage and price determination________________
Maintenance of present standards of working conditions____________
Labor standards in the New York metropolitan area_______________
Attempts to remedy conditions within the dress industry_______________
Intensified problems
Beginnings of cooperative effort________________________ ___________
Encouragement needed from women purchasers____________________
Problems of the neckwear and scarf industry
Home work on infants’ and children’s hand-made dresses___ _. _______
Stabilization of the millinery industry______
Season and fashion effects upon millinery workers__________________
Methods of control




United States Department of Labor,
Women’s Bureau,

Washington, August 26, 1936.
Madam : This bulletin was prepared at the request of representa­
tives of eight national women’s organizations, meeting with the
Women’s Bureau and a representative of the National Garment
Label Council to consider feasible methods of achieving the woman
buyer’s cooperation in the new movement for industrial stabiliza­
tion in the coat and suit and millinery industries. It will bring
the matter sharply before local women’s groups, and it is hoped
it will result in effective support of this movement for maintaining
high standards of working conditions.
The bulletin was written by Bertha M. Nienburg, Assistant Di­
rector of the Bureau.
Respectfully submitted.
Mary Anderson, Director.
Hon. Frances Perkins,
Secretary of Labor.












rlfd. [Inder fair
Labor Standards


A Policy Insuring Value to the Woman Buyer and a
Livelihood to Apparel Makers
American women spend from a billion and a half to two billion
dollars annually for their own and their children’s suits, coats,
dresses, hats, and neckwear. They give employment thereby to
300,000 apparel makers, whose earnings in turn, of course, supply a
part of this billion and more purchase money. The buying of the
American woman affects the earnings of these 300,000 clothing and
millinery workers as it affects workers in no other line of manu­
facture, for her month by month response to fashion marks an
instant rise or fall in the plane of their livelihood (1, 2).
The woman purchaser’s patronage is a power that carries with
it responsibility for conditions in the women’s and children’s apparel
industries. And in meeting this responsibility she is also guarding
the interests of herself and her family.
The woman purchaser of apparel is now as ever interested pri­
marily in securing fair value for money expended. Now as ever she
seeks fair value in terms of attractiveness of style and quality of
workmanship and materials. Her search for full value for her
dollar is thwarted in just the degree in which conditions pervading
this industry hamper production of good values. Uneconomical
methods of operation in entire branches of manufacture; unsound
management; waste of human effort, of materials, and other re­
sources; competitive tactics forcing production costs to too low
levels; workrooms overcrowded, badly lighted, lacking ventilation
and sanitary facilities; these and other conditions enter into the price
the woman purchaser pays for what she gets. The men and women
who make the garments or hats feel immediately the effects of organ­
ization and management inefficiencies in lowered earnings, longer
hours, recurrence of periods without work, fatigue and illness, and
lowered morale. The woman purchaser is not usually aware of the
factors that determine the prices she pays for her coats or suits or
dresses or hats. But whether she pays in lower quality of merchan­
dise or in higher prices, conditions within these industries which,
Note.—References indicated by figures are given on p. 22.




in the main, have grown out of the retailer’s efforts to gage her
fashion desires correctly are affecting the values she receives for her
Today, for the first time in the history of the women's apparel industry,
the woman purchaser is able to serve her family’s interest intelligently
while she serves the collective interest of the workers in this industry. For
today over four-fifths of the employers and the employees in two branches
of the apparel industry have banded together and are inviting the woman
purchaser to join them in a cooperative effort to solve their intricate and
essentially common problems.
The experience of half a century and the cooperative activities ini­
tiated by the National Recovery Administration convinced thought­
ful men and women in the women’s coat and suit industry and
in the millinery industry that “fair and equitable standards of labor”
and “standards of fair commercial practice” could be established and
maintained permanently only through the cooperation and system­
atic effort of employer, employee, and consumer. Accordingly, vol­
untary organizations were formed, representing all groups in each
industry, to “promote the common welfare of the industry and the
public good.” These are called the National Coat and Suit Indus­
try Recovery Board, organized in July 1935, and the Millinery Sta­
bilization Commission, formed later in the year. The creation of
these two agencies merged effectively the apparent conflict of group
interests; nine-tenths of the member concerns in the coat and suit
industry and four-fifths of the firms in the millinery industry agreed
to far-reaching objectives and to support effective administrative
control. Bringing together over 2,200 members of an industry and
representatives of 20,000 women and over 30,000 men employees, in
a cooperative effort to eliminate unfair trade practices and to better
labor conditions in the coat and suit industry; bringing together
over 1,100 firms and representatives of over 25,000 employees in
the millinery industry; has been a tremendous task and one worthy
of public admiration and support. These group-interest mergers
represent a new and fundamental effort at industrial self-regulation
in industries made up of many small units. That they have within
themselves the seeds of life is shown by their continued growth
after the judicial extinction of the N. R. A. under which they were
brought into existence.

Shall women’s clothing be made under conditions like this?


Or under conditions like this?


.Jtw ^

The Consumers' Protection Label guarantees sanitary working conditions.

90858°—36------ 2


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MfH Under Fan
Labor Standards


Never before has industrial self-regulation been attempted among
so large a number. But the one-tenth and one-fifth minorities that
have refused cooperation are a constant menace to the 90 percent
and 80 percent majorities in the great forward movement. A tem­
porary undercutting of prices of coats and suits or hats may force
the weaker concerns who are cooperating to give way. The woman
purchaser can thwart the attempts of these minorities to undermine
a movement that bids fair to assure to her, permanently, good mer­
chandise value for her money through the production of such
merchandise under adequate wage scales and excellent working con­
ditions. By recognizing these attempts for what they are—a tem­
porary lowering of price to secure eventually a higher profit—and
by showing this recognition through purchasing only coats and suits
and hats produced by the firms operating under the two boards, the
woman buyer will contribute her share to the joint effort to maintain
better conditions for worker and employer and to secure better
garments at lower prices for herself and her family.
This does not mean that she must pay a higher price today for labeled
garments, hut rather that from today on a more efficient industry will give
her better value for her dollar if today she upholds its initial efforts at
industrial stabilization. The new opportunity for the American wo­
man to serve herself, her family, her community, and her country
lies in the fact that now she acts with and through an overwhelming
majority of the producers and workers, thus assuring her a complete
merchandise range, whereas in years gone by the socially minded
woman had to work with relatively few firms, and those generally
unorganized, against a large number of undercutting concerns. Her
choice in the earlier efforts was usually sharply limited. She had
really to search for labeled goods. Today it is more a matter of
being on her guard lest an unlabeled garment slips into her purchases.
The Consumers’ Protection Label.
On every woman’s, misses’, child’s, or infant’s coat, jacket, cape,
wrap, riding habit, knickers, suit, ensemble, and skirt, in whole or
in part of wool, silk, velvet, plush, or purchased knitted materials,
made by any firm complying with the labor and trade agreements





set up under the National Coat and Suit Industry Recovery Board,
is stitched a Consumers’ Protection Label. This blue-lettered label
of white satin is sewed where the lining joins the facing at the waist­
line or as the sleeve lining is attached. To the lining in every
woman’s and child’s hat made under such an agreement, whether
of felt, straw, or cloth, is stitched a white, black-lettered Consumers’
Protection Label. Such label is the woman purchaser’s guarantee
that the garment or hat has been made under sanitary conditions,
that the makers of it have received current wage rates, and that her
purchase of it in preference to an unlabeled article will lend support
to the movement to bring about an efficiency within the coat and suit
industry and the millinery trade that will lead to better value for
price paid.
The label is found on coats and suits and hats priced from the
lowest to the highest levels. If the coat has a label stitched to its
lining, a woman may buy a winter coat for $20 with the same assur­
ance that it is made under sanitary conditions and at standard rates
of pay as if she buys a $150 coat with the label attached. An effort
is being made by firms using the label to fix piece-work rates on
either garment so that they will yield the worker approximately
the same earnings. On the cheaper coats, the orders for which are
larger than for the expensive coats and workmanship less fine, the
worker can turn out many in the same time that it may take to make
one expensive coat. Therefore, while the labor cost on a $60 coat
may be $9 and on a $150 coat $25, the hourly earnings of the workers
under the same working conditions will approximate the same
amount in firms complying with Consumers’ Protection Label
If there is no label attached to the coat and suit or hat, it matters
not how high the retail price, the consumer has no assurance of
ihe conditions under which the garment or millinery was produced.
In years past, when consumer groups have attempted to use a
label, the efforts were necessarily impeded by the impossibility of
continuous checking up by such groups on a number of manufac­
turing establishments. Today employees and employers are assum­
ing full responsibility for the inspection within the coat and suit
and millinery industries; a label is not sewed on a garment or hat
by the employee if there is any question of compliance of the em­
ployer with the collective agreements. While in years past a con­
sumer desiring to support the Consumers’ League label had diffi­
culty in finding garments that bore it, today she will find
approximately nine-tenths of the coats and suits and four-fifths of
the hats carrying a label.
Individually and collectively, women purchasers may support this
outstanding attempt at cooperative efforts of employer and employee



to put the coat and suit and millinery industries on an efficient basis.
Women’s local clubs may appoint an industrial committee to assure
coat and suit and millinery merchants in the community of the
women’s decision to buy only goods bearing the Consumers’ Protec­
tion Label. Real support can also be given to the movement by
every woman who goes shopping if she will promptly call the sales­
person’s attention to any unlabeled coat or suit or hat that she dis­
covers. Reports to the firms’ buyers that the absence of labels
is quickly noted and goods are rejected are passed on to the 10 and
20 percent, recalcitrant manufacturers or contractors who have been
unwilling to cooperate with other employers and employees in the
solution of the industries’ difficulties, and whose undercutting may
again bring back the demoralization that lias so often affected these
industries and their workers. This 10 and 20 percent will respond
to the woman purchaser’s demand for label goods, as a business
The influence of label patronage on other apparel industries.
It has taken more than a half century for the coat and suit, the
oldest factory trade in the women’s outer apparel industry, to effect
this organization for its stabilization. Other branches of the in­
dustry are not yet ready to solve their intricate problems by such
joint effort. The women’s and misses’ dress industry is making
much headway, but it has not achieved the popular acceptance of
regulation for common objectives that will warrant issuance of a
label giving complete assurance to consumers. The neckwear in­
dustry has achieved certain standards within the factory but has not
been able to eliminate the home-work evil. And the children’s and
infants’ dress industry has not started to cope with the home-work
problem on hand-made dresses.
The concentrated patronage of women purchasers of coats and
suits and hats bearing the Consumers’ Protection Label will serve
as a stimulus to the many concerns in the dress industry to bring
about more effective methods of control over the conditions in this
industry. Possibly in another year the dress industry will have
lessened the degree of conflict within its ranks and will be ready to
call for the woman purchaser’s support of a dress label.
Outspoken disapproval by mothers of the making of children’s
and infants’ hand-made dresses in homes where conditions cannot be
controlled is needed before the children’s and infants’ dress industry
will give serious attention to its elimination.

As indicated, the support of women buyers of coats, suits, and
hats bearing the Consumers’ Protection Label is an important fac­
tor in upholding efforts against the disrupting influence of a minority
within these industries. But there is a further responsibility for
the common good attached to the powder which the American woman
wields over the apparel industry. Whether rightly or wrongly, her
fashion vagaries stand accused of most of the evils within each of
the women’s and children’s apparel industries. Few women would
wilfully demand such a continuing change of styles as would make
insecure the earnings and health of some 300,000 other families.
But collectively they are blamed for having brought about the
Serious conditions so difficult to overcome in each of the apparel
Is it not time that organized women’s groups examine these
charges? That they study the complex conditions within these
industries to determine their own responsibility ? If they are guilty
in only a small degree, does not an intelligent self-interest call for
constructive action that will clear women of such an indictment ?
The women’s outer garment and millinery industries are vital to
the country’s welfare. Their contribution to the country’s wealth
through manufacture from raw materials is exceeded by only five
other industries. They are exceeded in numbers of persons given
employment by only eight other industries (3). Their contribution
to national wealth and mass purchasing power is, therefore, of con­
cern to every family in the land, whether the income of such family
be derived from farm, mine, factory, store, or office. Efficient func­
tioning in so important a branch of manufacture and adequate earn­
ings and healthful working conditions for so large a number of
persons will find their repercussion in purchases of more food and
furnishings and homes and in a demand for more and better profes­
sional and personal service. All such developments will redound to
the welfare of families apparently remote from the women’s apparel
Many American women are organized in groups for civic better­
ment and to promote their own and the general welfare. The exist­
ing economic problems in the several branches of the women’s outerapparel industry are presented herewith for their consideration so
that they may assess woman’s responsibility for these difficulties and
determine her obligations to work directly with retailer, manufac­
turer, and worker for their elimination. The common interest of
all groups lies in employment relations that will bring about low
unit cost of production through a high level of efficiency due to good
wages and good working conditions.



Students of fashion state that basic style changes follow closely
general economic, political, and social changes and that general
style trends spread over several years. However this may be, the
retail women’s clothing department buyer believes that the responses
of women purchasers to new fall or spring styles cannot be prophe­
sied with sufficient accuracy to risk stocking a supply of garments
of any one fashion. Rather, he prefers to display a large variety
of styles before placing even substantial orders. After initial sea­
sonal buying has indicated trends, he places orders with the manu­
facturer for quick delivery. Then, too, the retailer insists that
continuous style changes are necessary to command women’s atten­
tion from month to month. The manufacturer, therefore, is called
upon for garments of great variety made up in small quantity for
quick sale. He is afforded little opportunity for planning his work
ahead of orders.
The jobber-contractor system of manufacture.
These merchandising ideas have lead to a development within the
manufacturing branch of the women’s outer apparel industry that
is distinct from that known in other industries. Instead of a cen­
tralization of manufacturing in relatively few large factories, in
line with the development of modern American industry, large-unit
selling agencies have been combined with many small-scale manufac­
turing plants. Retail store buyers from all sections of the country go
to New York to look over the coming season’s olferings. For their
convenience, “jobbers” display many styles in their showrooms. It
is from “jobbers”, in large measure, that the retail buyers order and
The jobber is not a mere wholesaler of manufacturer’s products.
At the beginning of each manufacturing season he makes or buys
designs for garments and purchases the materials he wishes made
up. He then calls in “submanufacturers” to quote prices on making
up different designs in specific materials. The jobbers have insisted
hitherto that bids from many submanufacturers were necessary be­
cause each experimented with many styles. As the retailer pressed
him for low wholesale prices, the jobber kept his manufacturing
costs down by competitive bids from a large number of submanufac­
turers. Men who were employees yesterday thus managed easily
to enter the ranks of submanufacturers, for little capital was re­
quired to rent a room and some sewing machines. Knowing little
of price determination or cost accounting they accepted work at



impossible prices and in turn were forced to reintroduce sweatshop
conditions to keep operating.
Employers who have tried to operate large factories and sell their
own garments have been compelled repeatedly, by this continuous
price-cutting tendency, to turn over part of their sewing to con­
tractors who produced garments for less than the cost of making
them in the manufacturer’s own factories. Then too, the short
seasonal periods of peak load of demand were handled more cheaply
by sending part of the work out to those contractors who close up
shop when there is no work than by maintaining a plant equipped
to handle the peak production of 2 months over a 12-month period.
Specific conditions in the New York metropolitan area.
The dress and coat and suit industries are concentrated in and
about New York City; within the metropolitan area, which includes
the region within a radius of 75 miles of New York City, in New
York State, New Jersey, and Connecticut, are produced 87 percent
of the Nation’s street and formal dresses and 85 percent of women’s
coats and suits (4). In 1935 there were only 250 regular manu­
facturers of dresses within this region, that is, firms who purchased
their materials, cut out garments, and sewed at least some, of the
garments on their own premises. These 250 firms are estimated to
have employed 12,000 workers. There were 800 jobbers who did
the purchasing of materials, designing and selling of finished gar­
ments, and thereby gave employment to as many persons as did the
manufacturers. And there were 2,250 submanufacturers or contrac­
tors, employing 82,000 persons to cut and sew dresses. The wages
and conditions of work of over three-fourths of the actual producers
of women’s dresses are dependent, therefore, upon the price level to
which 800 jobbers have been able to force 2,250 contractors (5).
Out of 1,906 firms in the coat and suit industry in the metropolitan
area, 622 were regular manufacturers, 360 were jobbers, and 924 were
submanufacturers or contractors. The larger number of regular
manufacturers in this branch increased the proportion of workers in
so-called “inside shops” or in regular factories; a smaller number than
in dresses, 24,700 out of an average of 45,500 employees on coats and
suits, were employed by contractors or submanufacturers. But even
so, a very large proportion of the firms employed fewer than 20
workers (6).
Competition among many weak forms disastrous.—Such an indus­
trial organization growing out of cyclical fashion trends carried in
its wake untold possibilities of disaster for employee, employer, and
the public. Even in the year of increasing business ending February
1935, 298 coat and suit firms went out of business in the New York



area and 353 new firms entered business (7). The turnover was
believed to be even greater in the dress industry.
Each little shop a potential sweatshop.—The State of New York
has struggled since 1880 to take the work out of the tenement home,
to eliminate insanitary and unsafe shop conditions. But after its
first 30 years of battling the coming and going of little shops from
one New York street to another, the Joint Board of Sanitary Con­
trol, set up by employee-employer action, stated “all shops from
the poorest in the attic or cellar of some old converted tenement to
the richest and biggest in loft buildings of the most modern type
suffered from various sanitary defects”, that is, there was a startling
inadequacy of protection against “fire dangers”, “dirty floors, ceil­
ings, and walls”, “defective plumbing”, “accumulation of rubbish”,
“lack of adequate wTater closets, washing facilities, and adequate
means of ventilation” (8). Conditions have been vastly improved,
but even in 1935 the industry considered it necessary to maintain
the Joint Board of Sanitary Control at the expense of all organized
groups in the trade to prevent any recurrence of these conditions.
Its work has now been taken over by the Union Health Center.
Wage difficulties,—In years now past, workers had to buy their
own sewing machines, their needles and thread, and pay for the
electricity they used. A difficulty that has not yet been relegated
to the past is securing payment for services at regular intervals
from the small contractor. But the most fundamental wage problem
growing out of fashion vagaries was and is the fixing of prices to
the contractor on thousands of different models so that they will
yield to worker and to contractor and to jobber each a fair income.
The seasonal factor creates still another very real problem. The
seasonal range of production is greater in the women’s apparel in­
dustry than in any other industry save only fruit and vegetable can­
ning and cottonseed oil. And the employment extremes are ex­
ceeded only by industries dependent on growing seasons and by ice
cream and butter manufacturing (9).
While the services of 60,319 men and women were required during
the week of October 13 to produce coats and suits for the fall and
winter season of 1934, only 29,524 were employed by December 8,
and in the week of June 2, 1935, only 19,416 persons; that is, three
times as many people are given employment at the high tide of
demand as at its low ebb. Nor does employment mean full days of
work with full pay envelopes. The amount paid workers varied
90858°—36------ 3



even more widely than the numbers employed; it was over five times
as great during the week of March 24 as in the week ending June 2.
In an industry that gave some employment to over 60,000 people,
only from 19,000 to 20,000 could count on some income during 52
weeks; another 20,000 had to earn in 29 weeks an income to support
families for 52 weeks; and some 10,000 to 20,000 others received pay
during only 17 weeks of the year ending February 2, 1935 (10).
Every homemaker will appreciate the difficulties of the wives and
mothers who must budget such irregular earnings over an entire
year. Every effort to lessen style changes so that orders can be filled
over a longer period before the fall or spring season is an easement
of many family worries and an important step in industrial stabili­
As has been stated earlier, the inside manufacturers, the jobbers,
the submanufacturers or contractors, and the employees in the coat
and suit industry have severally merged their interests to “promote
the common welfare of the industry” by the formation of the National
Coat and Suit Industry Recovery Board. This administrative body
is governed by an executive board selected from the four regional
boards that administer the industry’s affairs in the four coat and
suit manufacturing regions of the United States. In the metropolitan
area, where 85 percent of all the coats and suits are produced, the
membership of the Metropolitan Regional Board is elected from the
International Ladies’ Garment Workers’ Union representing the em­
ployees, from the Industrial Council of Cloak, Suit, and Skirt Manu­
facturers, Inc., representing the inside manufacturers, from the
Merchants’ Ladies’ Garment Association, Inc., the association of job­
bers, from the American Cloak and Suit Manufacturers’ Association,
Inc., representing the contractors, and from the Infants’ and Chil­
dren’s Coat Association. In the other regions, employees and employ­
ers from different cities are elected to the regional boards.
Control of the jobber-contractor relationships.
The problem of jobber-contractor relationship is vigorously at­
tacked by this organization. In an amendment to the board’s consti­
tution, all members of the body who employ or deal with contractors
or submanufacturers must list those actually required to produce
their garments. While these may be changed from time to time as
business warrants after a hearing before the local compliance board,
the number of contractors is limited fairly closely to the seasonal
requirements of the market.



Competition among contractors is sharply curtailed.—Member
concerns employing contractors or submanufacturers agree to pay
producers, for overhead, a minimum percentage of the direct labor
cost in the production of garments. They also agree to pay an
amount for labor cost sufficient to enable the contractor to pay work­
ers the prevailing wage rates and earnings set up in collective agree­
ments within the region, or the actual rates of earnings fixed by
specific collective or individual contractual agreements.
Scientific attempts at wage and price determination.
To determine what the productive labor costs on any style of coat
or suit should be to yield specific earnings to the worker of average
skill, a labor bureau has been set up in the metropolitan area. This
bureau is ascertaining the time required in manufacturers’ and con­
tractors’ shops for workers to produce standard types and grades of
garments, so that a scientific basis may be available for determining
prices of production and piece rates for the various crafts in place
of the competitive price system existing in the industry. Today the
various persons concerned in the price the jobber makes to the con­
tractor adjust piece rates together; that is, the representative of the
workers, the contractors, and the jobbers, as well as a representative
of the labor bureau, work out equitable rates. Instead of continuous
undermining of one member of the trade by another, all members are
working together for their mutual benefit.
Maintenance of present standards of working conditions.
The constitution of the National Coat and Suit Industry Recovery
Board provides for the maintenance of present standards of working
conditions in the following terms:
Article V.—Hours




Other Standards


Working Conditions

1. If a member concern of this body is in collective or individual contractual
agreement with labor, said member concern agrees to maintain the standards
and provisions of said agreement.
2. If a member concern of this body is not in collective or individual contrac­
tual agreement with labor, said member concern agrees to establish and/or
maintain at least the minimum standard of wages and hours and working con­
ditions established through collective bargaining between employers and workers
in the region in which said member concern is located.
a. If for any reason these standards cannot be determined, then the stand­
ards of wages and hours and working conditions provided by the Code of Fair
Competition for the Coat and Suit Industry applicable to the member concern
in question as of May 1, 1935, shall be deemed the minimum standards to be
established and/or maintained by said member concern.



Labor standards in the New York metropolitan area.
Collective agreements in the New York metropolitan area under
employers’ organizations and employees’ unions call for the following
Cash wages shall be paid regularly each week. A minimum wage
scale is set up for each craft that is paid by the week. Workers in
crafts paid by the piece are guaranteed a minimum hourly rate, lower
than the basic rates used in fixing piece rates for each craft on each
garment design. The 'week’s work consists of 35 hours in the first 5
days of the week, a regulation which is intended to spread the work
over more weeks in the year. When an employer cannot provide
full-time work to all his employees, the work shall be equally divided
among all who are competent to do the work.
For the year ending February 1935, operating under approximately
the same terms as are given in this agreement, the average earnings
of men coat and suit workers in the New York area were $1,243, and
those of women were $758. The wTorkers in the inside shops had
average earnings of $1,305, and those working for contractors of
submanufacturers in the New York area had average earnings of
$880 (11).
During the life of the agreement there shall be no strike or lock­
out. All disagreement shall be settled by an impartial chairman
approved by all parties.
The conditions of employment reached through collective agree­
ment in the several regions vary as the character of work and type
of organizations within the industry vary. Year’s earnings are
slightly lower for both men and women than in the metropolitan
Any member who violates a wage provision must make up the
difference; if other provisions are violated, the concern is liable for
damages and cost, of investigation and hearings. Expulsion results
from intentional failure to abide by the constitution, bylaws, and
regulations of the National Coat and Suit Recovery Board.
All coats and suits that are manufactured under the terms of the
board bear a Consumers’ Protection Label. This label is public
notification that the garment has been made under sanitary conditions
and by employees and employers whose cooperative effort is bringing
much needed stabilization to the industry.

Every effort is being made by the dress industry to prevent a return of sewing to the back rooms of private homes

as shown in the picture.



While the dress industry has the same structural weaknesses as
the coat and suit industry and consequently the same general prob­
lems to overcome, complicating factors have increased the obstacles
in the way of cooperative study and regulation.
Intensified problems.
In the first place there is no clear demarcation between the dresses
made by this so-called dress industry and the cotton wash dress
made in the cotton-garment industry. Originally the cotton wash
dress was a cheap house dress produced in large volume by the
sectional method, requiring only semiskilled operatives. Today some
of the cotton wash dresses made under these conditions have been
carefully styled for street or afternoon wear, and consequently com­
pete with the cheaper dresses made by skilled operatives in the
dress industry. In its lower price levels, therefore, there is com­
petition which is not under the control of the dress industry today.
Secondly, the numbers as well as the proportions of jobbers and
contractors: in the dress, industry are much larger than those in the
coat and suit industry. In the New York metropolitan area, about
70 percent of the firms in the dress industry are contractors or
submanufacturers and about 24 percent are jobbers, whereas less
than half of the coat and suit concerns are contractors and less
than 20 percent are jobbers. While there are 3,300 separate con­
cerns in the New York metropolitan area alone to bring into agree­
ment in the dress industry, there are but 1,906 in the coat and suit
industry in this area.
And then again, the greater rapidity of style turnover in the dress
industry has necessitated heavy mark-downs in the dress departments
of retail stores. In 1935 women’s dress departments had mark-downs
of 16.6 percent, popular-priced dresses of 12 percent, and junior and
misses’ dresses of 13.5 percent (12). Dress department buyers have
counted on a high purchase discount rate from jobbers to reduce the
loss due to these sharp mark-downs. But even so, dress departments
of department stores operated at a loss in 1935, while coat and suit
departments were profitable. Consequently the pressure of lower
prices or higher discount rates is great, and competition among
jobbers is sharper than in coats and suits.
A reason, and probably a very vital reason, given for the rapid
turn-over of dress styles is “style piracy.” An originator of designs
no sooner has his or her dresses appear on the market than they are
copied in cheaper models. Once appearing in cheaper-priced dresses,



the design has no value in the high-priced dress field and new designs
must be introduced.
The larger number and greater turn-over of styles in the dress
industry also make it more difficult to reach any scientific basis of
determining equitable piece rates for production. In fact, the com­
petition on low-priced dresses is such that even the union has agreed
to lower minimum wages on dresses wholesaling for less than $3.75.
These factors have prevented the degree of cooperation among
the various elements in the dress industry that is such an outstanding
achievement in the coat and suit industry. In metropolitan New
York, the dress industry has two contractors’ associations, two job­
bers’ associations, as well as an organization of the inside manu­
facturers and one of employees; that is, there are five employer
groups to bring together instead of the three that would represent
each element in the industry.
Beginnings of cooperative effort.
These five associations and the International Ladies’ Garment
Workers’ Union have agreed to representation on one administra­
tive board, which interprets the. various agreements each has entered
into through collective bargaining. An impartial chairman enforces
the agreements. In the metropolitan area attempt has been made
through collective bargaining to solve the problems of the industry
in much the same way as is done under the coat and suit industry
where firms have entered into relationship with the International
Ladies’ Garment Workers’ Union; that is, excessive competition is
limited by requiring a designation of needed contractors by each
jobber and limiting the use of contractors to those entering into
agreement with the union as to minimum wage rates, hours of work,
and other labor conditions.
Price floors are established, where prices on different styles of
dresses are determined by representatives of the jobber, the con­
tractor, and the workers involved, and a price adjustment bureau
has been established. The enormity of the task of attempting to de­
termine the labor involved on different styles of dresses and the piece
rates necessary to yield the same earnings to workers and approxi­
mately the same profit to contractors is indicated by the fact that
from March 20 to May 15 of this year the price adjustment bureau
had to settle disagreements on 20,841 different dress styles (13).
While these efforts at solution of the dress industry’s problems are
forward looking, the conflict among the several groups within the
industry is still too great to have resulted in the submergence of
individual viewpoints and the acceptance of plans for the general
welfare. The administrative machinery is not sufficiently strong to
be sure it can control individual units without a greater degree of



popular support. The dress industry is not yet in a position, there­
fore, to attach labels to garments as the consumer’s assurance of good
conditions in the shops in which dresses are made.
Encouragement needed from women purchasers.
But the woman purchaser can help to bring about a greater spirit
of cooperation within the dress industry, can help to bring about a
more continuous flow of work, and avert the constant danger of rein­
troduction of the sweatshop. Her patronage of the Coat and Suit
Consumers’ Protection Label will be assessed by the dress industry.
If it facilitates that industry’s cooperative efforts toward general
betterment, it will serve to persuade the various elements in the dress
industry that the advantage to all lies in a willingness to support
individually and collectively regulations leading to general welfare.
The price of rapid restyling to the retail store, the contractor, and
the worker has been discussed. The woman purchaser pays for it,
too, in high retail mark-ups on new dresses to help to sustain the
mark-down after garments have been in stock, and in the outmoding
of dresses before they are worn. Do the majority of women pur­
chasers really demand the vast number of differently styled dresses
now to be seen in any dress department? Do they insist on a new
array of dresses whenever they shop? These are subjects to be
discussed by women’s clubs in the light of the sinister consequences
of rapid style changes to so many families. Can women purchasers
themselves help to stabilize the dress industry by insisting upon
better design, quality, and workmanship and less emphasis on differ­
ence? Is it to their own interest as family income managers to steady
the style changes ?

Just as the dress industry presents more intensive problems than
the coat and suit industry, so the neckwear and scarf industry has
even greater difficulties to overcome than those in the dress industry.
Today women may be wearing elaborate lace and embroidered neck­
wear, tomorrow a simple scarf, and a few months later no neckwear
of any kind. To attempt to bring stability to an industry and good
employment conditions to its employees under such style variations
is a herculean task. Yet about 4,000 persons are dependent upon, and
a business of $25,000,000 has been built up about, such style uncer­
tainties (14).
The link between this industry, which has its own association of
employers and its own union of employees, and the dress industry
further confuses the situation. Some dress manufacturers produce
the neckwear for their own dresses. Others buy it of neckwear manu­
facturers who work for them. Then there are the regular manu­
facturers who design, manufacture, and sell at wholesale and retail
and the jobber and the contractor as in the dress industry. But each
of these elements in the industry sends sewing out to the home, as
was done in the dress and coat and suit industry in years now happily
past. Thus the jobber or manufacturer wishing to avoid payment
of contractors’ overhead may send work direct to the home worker.
The contractor and his employees cannot survive under such a sys­
tem nor can any standard of sanitation or wages or hours be main­
tained in scattered homes. Then, too, the sweatshop of earlier days
is revived as a home worker accepts more work than she can do and
distributes it among her neighbors.
The agreements entered into between the Ladies’ Neckwear
Workers Union of Greater New York and members of the National
Women’s Neckwear and Scarf Association attempt to control home
work by requiring the same rates of wages in the home as are paid
for the same type of work performed in the factory. No home work
is to be given out unless one-half the articles of each type are pro­
duced in the factory or contractor’s shop. Even if a force of inspec­
tors were adequate to enforce such measures of control, difficulties
would arise. While some shops pay a piece rate that could be applied
to home work, others operate on a time basis, specific rates being paid
to each craft. A time rate is not a feasible method of paying home
workers, as the time put in by the home worker is beyond the control

Attempts to maintain wage standards in neckwear factories are almost impossible
while home work continues in the industry.



of the employer. Consequently it is not possible to determine
whether home workers working at a piece rate are receiving the same
amount that shop workers get who are paid in rates of from 40 cents
for trimming to 60 an hour for sewing-machine operating.
Then, too, New York firms scatter home work through New Jersey
and Pennsylvania, so it is not easy to follow up and check.
The difference in earnings of factory workers and home workers
is pronounced. A woman sewing collars by hand in an inside shop
makes 42y2 cents an hour. An experienced factory worker sewing
with her daughter at home is paid 20 cents for a collar that requires
sewing piping to a paper pattern and fagoting it to the main piece;
sometimes they can produce two collars an hour or make 20 cents
apiece—less than half the factory woman’s wage. Other experienced
collar makers who embroider collars at $2.65 for a bundle of 50
average 21 cents an hour. Less experienced workers paid 11 cents
and 9 cents for forming and sewing piping decorations on jabots
have earned 7 and 5 cents an hour (15).
The attempt to maintain standard wage rates in shops that can
be visited is well-nigh impossible while home work remains in the

But exceeding all other woven apparel branches in its failure to
eliminate the home-work evil is the infants’ and children’s hand­
made garment industry. Children’s tailored coats are made by the
coat and suit industry and will bear a label if made under good con­
ditions. But not so the little hand-made dresses or sacques that look
so dainty. While many of these are made in China, Puerto Rico,
and the Philippines, New York, Pennsylvania, and New Jersey are
large producers of this apparel. Scattered groups of home workers
are found as far away from the New York market as Texas.
These are some of the rates and earnings of individual women who
worked on children’s garments in Pennsylvania or New Jersey in
the spring of 1936 (15) :

9 rows of diamond smocking on dress fronts, size 4_____
5 rows smocking on dress fronts, size 12
Turning under collar edges and fagoting on lace edge;
inserting fagoted squares in collar
Cutting and turning scallops on child’s dress
Cross stitch, French knots, and lazy daisy design on
child’s dress
Cable stitch, gathering front of child’s dress
Lazy daisy leaf and rose design on each side of dress
Lace stitching to two sides of collar, and collar turned.
Buttonholing 3 small pieces of applique to skirt in 3
Hand hemmed and buttons attached
Whipping collar edge■.
Sewing pieces of braided thread to sides of dress and
making loops for belt
Sewing pieces of braid to form loops
Embroidering rayon baby caps and sacques
Embroidering baby’s crepe jacket; sewing lining and
jacket together and crocheting outer edges

Price paid per Earnings per
dozen dresses

$0. 60
. 35

$0. 10
. 06

1. 30
. 60

. 06

. 25
. 23

. 18

. 24
. 09

. 04

. 90
. 56
. 14

. 04
. 14

. 40
. 04
. 80

. 11
. 10
. 13

2. 75

. 08

Women like their children’s dresses to be hand-made or have hand­
work touches. There is no adequate reason why this desire should not
be met by production in sanitary shops in which standard wages are
paid to skilled workers. It is not so done only because it is far
cheaper to throw the burden of overhead and low wages on the woman
home worker.

The home worker is paid $2.75
a dozen sacques for embroid­
ering them in 5 colors, sewing
linings to jackets and crochet­
ing outer edges.

1 1 -j
i- : ;vi: •


V' t

The home worker is paid 60 cents
a dozen for cutting the scalloped
edge, turning it and other faced
edges, and creasing same.


$ Mmm


SB #«

About half the workers on millinery are women trimmers and one-tenth are men

In spite of the fact that millinery has been produced on a custom
basis much longer than other apparel and that demands for individu­
ality and style change are even greater than in the dress industry,
four-fifths of the firms engaged in this production have joined with
their employees in the establishment of a millinery stabilization com­
mission to regulate the affairs of the industry. This represents an
intelligent recognition of the interdependence of the welfare of em­
ployee and employer by New York, Philadelphia, and Middle West­
ern cities’ firms. It represents a heroic effort to hold the gains made
by the year of cooperation under N. R. A. and to prevent a return to
the disastrous conditions which had prevailed for many years before.
Season and fashion effects upon millinery workers.
While women will recall the change from the ornate hat of 10 years
ago to the simple hat of today, few realize that this shift threw thou­
sands of persons out of work and caused many firms to close up shop.
In 1927 there were over 33,000 craftspersons making and trimming
women’s and children’s hats; by 1929 more than a thousand could find
no employment in the industry and by 1931 almost 6,000 others were
unemployed (16).
Nor do women recognize that seeking trimmed straw hats in spring
and tailored felt hats in the fall results in unemployment, for some of
the trimmers and sewers who worked on straw hats cannot be placed
in the fall and some blockers required for fall hats can find no posi­
tions in the spring. Twice a year almost half the workers in the
industry are laid off. Some women seeks jobs in other fields—usually
unskilled jobs; and they return to the industry in which they are
skilled, season after season. Many millinery workers have no partic­
ular employer but move about from one shop to another, certain of
their craft skill but not of an employer.
The instability of the worker is almost equaled by that of the
employer. Prior to 1933, the popular-priced hat sold at wholesale
for $24 a dozen; in 1934, 60 percent had to be sold at $12 a dozen
wholesale. In 1934, 20 percent of the millinery manufacturers failed
(17). These manufacturers are bona fide producers; that is, they buy
their own materials, manufacture hats, and sell them at wholesale.
But small shops are made necessary by the rapidity of style changes
and the sharp seasonal rises and falls. Flexibility is of vital impor­
tance to the millinery industry.




As the industry is organized, a few houses originate hat designs
by employing skilled designers who keep close touch with Paris
fashions. The larger number of manufacturers are copyists; they
watch fashion shows and openings and make up what they believe to
be popular designs, or they reproduce hats, which a wholesaler or
retailer brings them to copy, in cheaper models. This style piracy
is regarded as one cause of rapid turn-over in styles, but efforts to
stop it have had limited scope; only the high-priced hat has original
design, and such hats represent a very small part of the total business.
The manufacturer buys his raw materials from large dealers, fre­
quently importers, and he sells to large wholesalers or retailers.
Sixty percent of all finished hats are handled by syndicates that rent
the millinery departments in stores scattered all over the United
States. These syndicates are large and buy in quantity, while manu­
facturers are small concerns. Singly the manufacturer has no bar­
gaining power. Being primarily a technician, usually he has not
been a keen businessman. He has given discounts and other conces­
sions to the buyers that have been ruinous to himself and his
Methods of control.
The Millinery Stabilization Commission is governed by a board
of three members not connected with the millinery business. Firms
controlling 80 percent of the production have entered into agreement
to abide by the trade-practice provisions of the former National
Recovery Administration code. They have agreed to maintain the
collective agreements entered into with the United Hatters, Cap, and
Millinery Workers’ Industrial Union. They hope, by developing a
spirit of cooperation in the industry, to bring individual employees
and employers together for common council.
The agreements covering working conditions aim to give employ­
ment to as many workers as possible. Weekly hours are fixed at 35,
with the understanding that overtime cannot be worked unless all
workers in the crafts affected are employed full time and unless all
available seats and benches are occupied. Sanitary working condi­
tions are required.
A minimum scale of wages is set up for each craft, a scale placed
high enough to make up for some of the irregularity of employment.
A higher scale is used as a basis for settlement of piece rates for the
average good worker. The piece-work prices are settled by employee
and employer price committees. If agreement cannot be reached, the
matter is submitted to millinery adjustment boards made up of repre­
sentatives of employees and employers and an impartial chairman;
decisions of these boards are binding.
While the Millinery Stabilization Commission counts on the unions
to police these labor agreements, they in turn throw their force behind



the union agreements, by preventing price undercutting and by
strengthening the manufacturers’ position in dealing with the whole­
sale syndicate and retail merchant.
The industry has no contractors and no home work. Its label is
a guarantee that the hat is made under sanitary conditions, at the
best wage rates the industry can now afford, and that the firms whose
goods carry the label are earnestly seeking to find a way out of diffi­
culties imposed upon them by a too seasonal and a too rapid fashion
Women buyers help by buying labeled hats. Can they spread the
making of hats over a longer period by spreading their buying?
Can they help to set up counciling groups which will determine style
demands months before retail buying has begun ?

(1) U. S. Bureau of the Census: Fifteenth Census, 1930. Apparel Retailing,
pp. 72-73.
U. S. Bureau of Foreign and Domestic Commerce: 1985, Retail Sales.
Release of February 1938.
Smaller sales figure derived by applying decrease in sales in department,
apparel, and mail-order houses from 1929 to 1985, to 1929 sales of
women’s, misses’, and children's and infants’ outer apparel and hats.
(2) Employment figures obtained from numerous statistics compiled for or by
N. R. A. code authorities for 1934 or 1935.
(3) U. S. Bureau of the Census: Abstract of the Fifteenth Census of the
United States, Manufactures, table 4, pp. 744-757.
(4) N. R. A. Division of Review: Evidence Study No. 9, The Dress Manu­
facturing Industry.
Coat and Suit Authority Mimeographed Statistical Tabulations, table 10.
(5) N. R. A. Division of Review: Works Materials No. 44, Some Aspects of
the Women’s Apparel Industry, p. 53.
(6) Coat and Suit Authority Mimeographed Statistical Tabulations, tables
12.2 and 21.
(7) Ibid., table 12.1.
(8) Joint Board of Sanitary Control: Third Annual Report, 1913, pp. 19-20.
(9) Kuznetz, Simon. Seasonal Variations in Industry and Trade, 1983, pp.
(10) Coat and Suit Authority Mimeographed Statistical Tabulations, table 2.
(11) Ibid., table 21.
(12) National Retail Dry Goods Association. Controllers Congress Report,
p. 11.
(13) Women’s Wear Daily, May 19, 1936.
(14) N. R. A. Code of Fair Competition in the Women’s Neckwear and Scarf
Manufacturing Industry, p. 81.
(15) Original data secured by Women’s Bureau agents in April and May of
(16) N. R. A. Division of Review: Works Materials No. 53, The Millinery
Industry, table 13,
(17) Ibid., p. 138,