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Registry No. 1637A-09 

NATIONAL RECOVERY ADMINISTRATION 

PROPOSED CODE OF FAIR CO,MPETITION 

FOR THE 

SHEET STEEL FARM EQUIPMENT 

MANUFACTURING INDUSTRY 

AS SUBMITTED ON AUGUST 31, 1933 

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UNIV. 0 . F !'lt.09. OUR PART 

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U.S. DE 

The Code for the Sheet Steel Farm Equipment Manufacturing Industry 

in its present form merely reflects the proposal of the above-mentioned 

in dustry, and none of the provisions contained therein are 

to be regarded as having received the approval of 

the National Recovery Administration 

as applying to this industry 

UNITED STATES 

GOVERNMENT PRINTING OFFICE 

WASHINGTON : 1933 

For sale by the Superintendent of Documents, Washington, D.C. - - - - - - P rice 5 cents 
SUBMITTED BY 

SHEET STEEL FARM EQUIPMENT ASSOCIATION 

(II) 
CODE OF ETHICS AND PRACTICES FOR THE SHEET STEEL 

FARM EQUIPMENT ASSOCIATION, AN AFFILIATED 

ORGANIZATION OF THE NATIONAL COUNCIL LIVE 

STOCR EQUIPMENT ASSOCIATIONS 

ADOPTED AT CHICAGO, AUGUST 16, 1933 

PRE.AMBLE 

The Sheet Steel Farm Equipment Association, a national trade 

association for this industry representing in its membership more 

than 75 percent of the production of sheet steel farm equipment in 

the United States, by action taken at a meeting in the City of Chicago, 

on the twenty-sixth day of July 1933 does hereby subscribe to the 

policy, provisions, rules, and regulations of the National Industrial 

Recovery Act. 

The Sheet Steel Farm Equipment Association, by a majority vote 

at this meeting, decided to corn.e under the provisions of this act 

which permit the voluntary adoption of a Code of Fair Competition 

and Practices and authorized the creation of an Executive Committee of five members to draft a code and present it to the Government for Presidential approval. 

CONDITION OF THE INDUSTRY 

The products of this industry are-sold principally to the farmer, 

largely through dealers. Due to the limited buying power of the 

farmer, this industry has been in an abnormally depre sed condition 

for the past several years. With the rapidly decreasing consumption of the products of this industry, competitive conditions have 

become extremely destructive, resulting in severe loss of wages for 

the worker, and in the destruction of the capital values and cash 

reserved for the producer. 

WHAT CONSTITUTES SHEET STEEL FARM EQUIPMENT 

Sheet steel farm equipment, as used in this Code, includes the following items: Stock watering tanks, storage or cistern tank , waterwagon tanks, grain tanks or bins, hog troughs or· feeders, well casing, 

tank heater , feed cooker , dip tanks, and other kindred product . 

ORGANIZ.A TION 

This Association is composed of manufacturer of galvanized steel 

or iron farm equipment, many of whom have formerly been allied 

with one of several steel tank associations~ a large part of whose 

activities consist of the manufacture of welded steel heavy gauge 

(III) 
IV 

tanks used for oil and gasoline storage and other similar purpo es. 

Inasmuch as the interests of this particular group are closely allied 

with the Live Stock Industry this Association was formed and is 

herewith affiliated with the National Council Live Stock Equipment 

Associations. 

ASSOCIATION OFFICERS 

Temporary officers of the Sheet Steel Farm Equipment Associations elected at a meeting of the Association in the city of Chicago 

on August 16, 1933, are as follows: President, E. P. Kreimendahl, 

Celina Mfg. Co., Celina, Ohio; Vice President, A. J. Klein, Klein 

Mfg. Co., Burlington, Ia.; Secretary-Treasurer, W. A. Zaloudek, 

Oakes Mfg. Co., Tipton, Ind.; Executive Secretary, H. L. Ashworth, 

125 East Wells St., Milwaukee, Wis. 

EXECUTIVE COMMITI'EE 

The Executive Committee consists of the following: E. P. Kreimendahl (Chairman), Celina Mfg. Co., Celina, Ohio; A. J. Klein, 

Klein Mfg. Co., Burlington, Ia.; W. A. Zaloudek, Oakes Mfg. Co.~ 

Tipton, Ind.; C. S. Riggin, J as. H. Watson Co., Inc., Bradley, Ill.; 

L. C. Harding, The Butler Co., Butler, Ind. 

MEMBERSHIP OF ASSOCIATION 

The membership of the Sheet Steel Farm Equipment Association, 

representing -- percent of the production of sheet steel f arm equipment in the United States, includes the following companies. 

l\tianufacturers of sheet steel farm equipment, repre enting the 

balance of the production of sheet steel farm equipment in the United 

States, which have been invited to become members of this Association bu! have not yet affiliated as members include the following 

companies. 

So far as can be determined by this Association the aboYe list of 

members and nonmembers include all of the factors engaged in this 

industry. 

The Sheet Steel Farm Equipment As ociation in b half of thi 

industry, does hereby submit and ask for approval of the following 

Code of Ethics and Practices. 
THE CODE 

ARTICLE I-PURPOSE 

This Code is set up for the purpose of increasing employment, 

main~aining fair and adequa~e. w~ges, and eliminating unfair trade 

practices, to the end of rehab1htat1ng the sheet steel farm equipment 

industry in all its phases and enabling it to do its part toward e tablishing that balance of industries which is necessary to the restoration and maintenance of the highest practical degree of public welrare. 

It is the declared purpose of the sheet steel farm equipment industry and adherents to this Code to restore the income of enterprises 

within the industry to levels which will make possible the payment 

of fair wages and a void the further depletion and destruction of 

capital ass€ts. 

ARTICLE II-PARTICIPATION 

Participation in this Code, and any subsequent revision of or 

addition to the Code, shall be extended to any person, partnership, 

or corporation in the sheet steel farm equipment industry who accepts his share of the co t and responsibility, as well as the benefits, 

of such participation by becoming a member of the sheet steel farm 

equipment association. 

No initiation or entrance fee shall be charged for membership in 

the Sheet Steel Farm Equipment Association, but there shall be 

levied against all members of the association annual dues in the 

amount of $25.00. Additional dues needed to finance the activities 

of the association in carrying out and enforcing the Code of the 

industry shall be levied against each member in proportion to the 

volume of its sales of the items covered by this Code. 

ARTICLE Ill-GENERAL 

(1) No provision of this Code shall be interpreted or applied in 

such a manner as to (a) Promote monopolies; (b) Permit or encourage unfair competition; ( c) Eliminate or oppress, or discriminate against small enterpri es in the sheet teel farm equipment 

industry. 

(2) This Code or any of its provisions may be cancelled or modified or any a pp roved rule issued thereunder shall be ineffective to 

the extent necessary to conform to any action by the President of 

the United States under section 10 (b) of the National Industrial 

Recovery Act. 

(3) Amendments to this Code may be proposed to the Executive 

Secretary by any member or members of the Sheet Steel Farm 

Equipment Association, or may be initiated by the Executive Com-

(1) 
2 

mittee and may be adopted by the affirmative vote of a two-thirds 

majority of the member of the as ociation, and when approved by 

the President of the United States shall be effective. Any amendments proposed shall be ubmitted in writing to all members of the 

as ociation not less than two weeks before coming before the association for action. 

( 4) The Chairman and the Executive Secretary of the association, 

subject to the approval of the Executive Committee, shall represent 

the Sheet Steel Farm Equipment Association and the Sheet Steel 

Farm equipment industry in all contacts with the Administrator of 

the National Industrial Recovery Act, or his agents, except if a 

member of the association shall feel aggrieved on account of the 

provisions of this Code or of an amendment thereto or rule or regulation made pursuant thereto such member shall have the right 

directly to present his position to the President of the United States 

or his duly authorized agent. 

( 5) The provisions, rules, regulations, and restrictions as et forth 

in this Code, when approved by the President of the United States, 

shall become binding upon all producers of sheet steel farm equipment within ten days after final approval. 

(6) Rights of W m·kers.-(a) Employees in the sheet steel farm 

equipment industry shall have the right to organize and bargain collectively through representatives of their own choosing, and shall be 

free from the interference, restraint, or coercion of employers of 

labor, or their agents, in the designation of such representatives or in 

self-organizations, or in other concerted activities for the purpose of 

collective bargaining or other mutual aid or protection, as provided 

for in Section 7 of the National Industrial Recovery Act. 

(b) o employee in the sheet steel farm equipment indu try, and 

no one seeking employment therein, shall be required as a condition 

of employment to join any company union, or to refrain from joining 

a labor organization of his own choosing, as provided for in section 

7 of the National Industrial Recovery Act. 

( c) Employers of labor in the sheet steel farm equipment industry agree to comply with the maximum hours of labor, minimum 

rates of pay, and other workino· conditions appro, ed or prescribed 

by the President of the United States. 

( d) It is clearly understood that the foregoing paragraphs do 

not impair in any particular the constitutional rights of the employee and employer to bargain individually or collectively as may 

be mutually satisfactory to them; nor do they impair the joint right 

of employer and employes to operate an open shop. 

( e) Nothing in this Co le is to prevent the selection, retention, and 

advancement of employees on the basis of their individual merit, 

without regard to their affiliation or nonaffiliation with any labor 

organization. 

(f) It i expressly stipulated that neither any provision of this 

Code nor the fact or manner of its preparation, presentation, adoption, or filing shall be construea as con tituting a waiver of any 

con titutional right which the several members of the Sheet Steel 

Farm Equipment Association or indu try might otherwise have and 

enjoy. Any such provi ion which may limit or abrogate any constitutional right is inserted under the unavoidable requirements of 

the ational Industrial Recovery Act a the same is understoo l by 
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said members and not voluntarily nor with their approval a a 

contractual relinquishment of such right. 

ARTICLE IV-ADMINI TRATION 

Enforcement.-The admini tration officer of this Code hall be the 

Executive Secretary of the Sheet Steel Farm Equipment Association. He shall be required to submit and to explain the provisions, 

purposes, and aims of the Code to all producers of sheet steel farm 

equipment, including members and nonmembers of the Sheet Steel 

Farm Equipment Association. 

Any producer of sheet steel farm equipment injured by the violation of this Code shall file with the Executive Secretary a written 

complaint setting forth the facts in the matter and requesting such 

relief as may be just. 

The Executive Secretary of the Sheet Steel Farm Equipment 

Association is authorized and directed to enforce vigorously, equitably, and without exception a system of discipline for violator of 

this Code or any of its rules, regulations, or provisions as follows: 

A fine against violator , in case where the violation involves a 

sale of sheet steel farm equipment, of an amount not to exceed fifty 

percent of the e tablished pri e of the equipment old. A fine against violator where the sale of equipment may not be 

involved, of an amount not to exceed five hundred dollars ($500). 

The Executive Secretary may use his di cretion, as circumstances 

warrant, in substituting an arbitrary fine for the percentage of sale 

plan. 

Violation of any or all rule of the Code may be considere l a 

separate offense for each and every day , uch rule are violated. 

If found necessary to the welfare of the industry or in support 

of the proper administration of this Code, the Executive Secretary 

may give full publicity to the f~ct regarding any violation by any 

per on of any rule or regulation of this Code, and the hearing and 

determination thereon, without any liability for libel ari ing 

therefrom. 

Any fines a sessed and collected shall be turned into the Association Treasury. Such money shall be available for a war ling finan cial 

damages to member injured by violations. Fines collected and not 

sou eel shall be applied to the Association1 operating budget. 

Any member o:f the Sheet Steel Farm Equipment A ociation 

or any producer of sheet steel farm equipment who is not a member 

of the association shall have the right to appeal from the ruling 

or decision of the Executive Secretary, and such appeal shall be 

heard by a representative Arbitration Committee of at least three 

per ons, such committee to be appointed by the Executive Committee of the Sheet Steel Farm Equipment Association from the 

organization of different members of the industry. Under this provi ion a separate Arbitration Committee shall be named to handle 

each appeal, and the membership of such committee shall be truly 

representative for the purpose of insuring the partie a fair hearing, but shall not include any members of the indu try connected 

with or in any way involved in the dispute in question. 

The decision of such Arbitration Committees may be appealed by 

either party to the association as a whole and the decision of the 
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a sociation shall be final and binding. If such association decision 

i not accepted and complied with by the complainant or defendant, 

the case shall be turned over to the Executive Committee of the 

industry for submission to the Administrator of the National Industrial Recovery Act. 

; tatistics and Reports.-The Executive Secretary shall have the 

power and authority to require from each manufacturer of sheetteel farm equipment from time to time such wage and labor reports, 

information, and records as shall be necessary to the adequate 

admini tration and enforcement of the provisions of this Code. 

The Executive Secretary shall have the right at all times to examine all records of every producer of sheet-steel farm equipment whenever such inspection is necessary for the adequate administration and 

enfo1rcement of the provisions of this Code. It is definitely agreed 

that any such information obtained by such inspection shall be of a 

strictly confidential nature, except insofar as disclosure of the facts 

so obtained may be necessary to the just administration of this Code. 

ARTICLE V - HOURS OF LABOR 

We agree that on and after the effective date hereof employers in 

the sheet-steel tank industry shall not operate on a schedule of hours 

of labor for their employees, excepting executives and their assistants and salesmen, in excess of forty ( 40) hours per week, averaged 

over a six months' period. 

(a) However, there shall be no restrictions on the number of hours 

which may be worked during any one day or during any one week, 

provided the average of forty ( 40) hours per week over a six months' 

period is not exceeded. 

(b) The above, ho,wever, is not to apply to hours of labor for repairshop crews, engineers, electricians, firemen, office, sales, and super• 

visory staff hipping, watching, and outside crews. 

ARTICLE VI-WAGES 

\Ve agree that on and after the effective date hereof the minimum 

wage which hall be paid by employers in the sheet-steel tank industry to any of their employees shall be as follows: Adult male labor, 

30¢ per hour; female and minor labor, 25¢ per hour. 

(a) It is und rstood that learners shall be exempted from proviion of thi ection for a period of twelve week from the date of 

their employment. 

(b) It i further under tood that ea1 ;h manufa turer hall ha,e the 

privilege of exempting from the proY1 ions of thi section a certain 

number of so-called· pen ioner employees · namely employees who 

by rea on of age or phy ical disability are not capable of performing 

a full dav' work but whom it i de ired to retain b2cau e of their 

long com1 ction with the bu ine . uch employee hall be reported 

eparately in the makino· f nece ary current labor reports to the 

Admini trator. 

'\Ve further agree that the above rate may be r vi ed from time to 

time in nch manner a will currently refl ton equitable adju tments 

to yariation in the co t of li, ing; uch adju tment to be ubject to 

the appr val of the Pre ·iclent f the nited State ·. '\Ye further 

agree not to employ any minor un ler the age of 16 ear . 
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ARTICLE VII-SEI,LlNG PRICE . 

It shall be an unfair method of competition for any producer of 

sheet-steel farm equipment to ell his product below his own cost, 

plus a rea onable profit. 

Co t to be interprete l a follow -· : 

(a) Current price of all mat rials n eel, inclncling freight. 

(b) Cost of all direct labor, including layino- out, fabricating, assembling, riveting, ·oldering, welding, tini hing, te tino- etc.; 

(c) Fixed expen e or overh ad coyer item. inclu Eng salarie of 

the AdministratiYe and ExecutiYe Officers (which mn t be figured 

commensurate ·with service performed), clerical help, hipping: 

credit expense, hop , uperinten lent and maintenance, normal advertising, and sales expen e. All di count· an l commi ion, rea~ona-ble depreciation on plant and equipment, ob ole cence, and any anrl 

all general cost and charge whether specifically enumerated or not. 

ARTICLE VIII-TRADE PRACTICE RULES 

The e trade practice rule as set forth in Group I for the Sheet 

Steel Farm Equipment A sociation are identical with the trade practice rules adopted by the Barn Equipment Indu try ancl which were 

approved by the Federal Trade Commi ion on July 11, 1929, and 

amended on September 19, 1930. 

GROUP I 

RuLE 1. Interference with contract.-.The wilful interference by 

any per on, firm, corporation, or association, by any means or device 

whatever, with any exi ting contract or order between a seller and 

purcha er of any product handled by the industry, or the performance of any contractual duty or service connected therewith, such interference being for the purpo e or with the effect of dissipating, 

destroyino-, or appropriating in whole or in part the patronage, 

property or business of another engaged in uch indu try, i unfair 

trade practice. 

RULE 2. Jl,Jisrepresentation.-The sale or offerino- for sale of any 

product of the industry with intent to deceive customers or prospective cu tomers as to the quantity, quality, substance, or size of such 

product i unfair trade practice. 

R1rr.E 3. Rebates.-The payment or allowance of secret rebates, refund , credits, or unearned discounts, whether in the form of money 

or otherwise, or the giving of premiums, or extending to certain purchasers, public institutions not excepted, special prices, term.s, 

services, or privileges not extended to all purchasers under like terms 

and conditions, is an unfair trade practice. 

RULE 4. Price discrimination.-Any discrimination in price between 

purchasers of the same class~ excepting discrimination in price on 

account of the difference in grade or quality of the product sold, i 

unfair trade practice. 

RULE 5. Defam,ation of character.-The defamation of a competitor by words or acts which call in question his busine integrity, hi 

ability to perform his contracts, his credit standing, or mi repre enta-
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tion of the grade, quality or reliability of his goods is condemned as 

unfair trade practice. 

RULE 6. Excess allowances.-The allowance of transportation or 

trucking charges in excess of the actual or published amount of such 

charges on products is an unfair trade practice. 

RULE 7. Soliciting eniployes.-The solicitation of the services of 

salesmen or other employes of other members of the industry without notice to the employer involved is an unfair trade practice. 

GROUP II 

RuLE 1. P1·ice Lists.-It shall be required that all members use 

uniform list prices on all classes of galvanized tanks and for such 

other products for which uniform list prices have been adopted. 

Any deviation from the following: A fair and equitable classification of customers shall be made by all manufacturers in this industry. There shall not be more than three classifications as follows : 

(a) jobber, (b) National Distributors, (c) retail dealers. Manufacturers in this association shall circulate to each classification that 

they regularly sell their price list for various izes, grades, and quantities of their products, stating clearly in said published sheets or 

catalogues such information as is necessary to correctly and accurately describe all products offered for sale and shall also publish 

credit terms, cash discount, freight, or other transportation charge 

allowances and that such published price sheets shall truly represent 

the sales prices, term , and conditions without any de, iation whatsoever therefrom. Price sheets before becoming effective shall be 

filed with the Executive Se~retary, as a matter of information, who 

shall inform. all members of the Sheet Steel Farm Equipment Association of all conditions contained in the price sheets so filed. 

Any violation of this plan by any producer of sheet steel farm 

equipment is unfair competition. 

R u LE 2. Dealers.-Definition: The term dealer for the purposes 

of this Code shall be defined as one operating a place of business, 

carrying a stock of goods, selling at retail and for the purposes of 

this Code shall be further limited to those dealers who handle lines 

kindred to Sheet Steel Farm Equipment, as, for instance, farm 

implements and hardware, lumber, water-supply materials or service; also general stores carrying hardware; and shall exclude retail 

dealers handling lines entirely foreign to the Sheet Steel Farm 

Equipment industry who have not in the past handled Sheet Steel 

Farm Equipment as a line. 

Nothing herein shall prevent a producer of Sheet Steel Farm 

Equipment from continuing to sell at regular dealers discount to a 

retail distributor who conducts a place of business and carries a 

stock of goods but who does not qualify under the strict interpretation of the foregoing definition, if at any time within five years 

la t pa t he ha been an active dealer customer on the book of such 

producer. 

RULE 3. J obber . . -Definition of J obber: The indu ·try hereby re- cor l. it approval of the :lefinition of a qualified manufactur 0 r or 

whole ale di tributor to be ne " ·ho e principal bn ine is . ellino- to 

the retail di tributor, carrie a well elected -tock of merchancli ~e 

buys in uitable quantitie ,Yareho1Le_ a re erve ,tock for retailer;:, 
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within a radius of economical distribution and convenience of service, resells in proper units to the retailer as economically as possible, 

assumes the credit risk, and such other obligations as are incident 

to the transportation, warehousing, and distribution of the products 

of the industry. . 

Discownt.-It shall be unfair competition for any producer of sheetsteel farm equipment to allow a discount to a jobber of sheet-steel 

farm equipment greater than 20% for stock shipment or 171⁄2% for 

direct shipment from dealer price list. It shall also be unfair competition for any producer of sheet-steel farm equipment to allow a 

discount greater than 20% for stock shipment or 171⁄2% for direct 

shipment from dealer price list to any national distributor. Any 

other purchasers shall be cla sed as consumers and shall not be sold 

at less than 25% above dealer price plus freight. · 

RULE 4. It shall be unfair trade practice for any manufacturer to 

consign stocks with dealers or jobbers. · 

Rm£ 5. It shall be unfair trade practice for any manufacturer to 

sell or offer for sale any merchandise carrying a private brand or 

without brand at lower prices than same quality of goods under 

regular or other brands. 

RuLE 6. T erms.-Terms of payment on all invoices covering sales 

to jobbers and dealers shall be not to exceed 1 % discount to jobbers 

and 2% to dealers from net amount for payment on or before 10th 

proximo or 30 days net. No cash discount allowed on transportation charges. On future orders taken for shipment at the manufacturer's convenience during the months of October, November, December, January, and February, a dating not to exceed 60 days beyond the first of the following month after shipment is made may be 

given, but in no case shall any dating be made extending later than 

April 1st, 2% April 10, 30 days net. 

RuLE 7. Freight allowance.-All prices to the dealer and to the 

jobber on direct shipments to customer will be F.O.B. factory, provided, however, any manufacturer shall have the right to equalize 

and/or absorb freight charges on nested tanks with any competitive 

point where other manufacturers or jobbers in competition may have 

factories or regular distributing warehouses. No freight equalization will be made on any tanks shipped singly. The Executive Secretary shall prepare a list of these competitive points which shall be 

circulated to the industry and no addition shall be made to the list 

without being passed upon by the directors. On shipments to jobbers' stock, carload rate of freight will be allowed. 

RuLE 8. Unifor1n guarantee.-Members of the Sheet Steel Farm 

Equipment Association may give to customers thereof a uniform 

guarantee or warranty as follows: "We guarantee this merchandise 

to be free from defective workmanship or material for a period of 

one year from sale thereof and agree to replace and repair at our 

option without charge, any merchandise sold under this arrangement 

within the time limits prescribed herewith F.0.B. factory and without allowance for repair and other liability therein." 

RuLE 9. It shall be an unfair trade practice for any manufacturer 

to make payment of or allowances for specific advertising expense 

in behalf of purchasers that would in any way have the effect of 

repre~enting a concession beyond the regular published price. 
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3 1262 08850 5242 

RULE 10. It hall be an unfair trade practice for any manufacturer 

to ell or offer to ell any products of the industry, excepting hog 

troughs and feeding pans, made from material procured from any 

ources of supply that is designated by the manufacturer or seller as 

• econd " or other than prime or fir t grade material in competition with product made of prime or first grade material- provided 

that houl l any manufacturer use 'second " or material other than 

prime or first grade in the manufacture of his products, excepting 

hoa troughs an l feeding pans, then all such products hall be clearly 

an l con picuou I y tenciled made of seconds ' and sold an<l invoiced a uch to hi customer. All such product hall not carry 

any form of guarantee as to service or length of life. 

RULE 11. Any teel mill which fabricates articles of merchandise 

de ignated under thi Code shall be subject to thi Code in every 

particular, and it hall be unfair competition for such miH to figure 

in the co t of uch article of merchandi e any material of their own 

manufacture at other than the publi heel re ale price~ of uch material when sold in carload lots. 

PRODUCTION RESTRICTIO::.\' 

vVe agree that becau e exi ting productiYe capacity far exceed the 

1ormal demand, not to increase our productive capacity for a period 

of 12 month fr m the effective date of this Code excepting a it may 

be normally increa eel through the substitution of new for exi ting 

equi1Jment or through more efficient method of manufacture. 

fn view of the foreaoing agreement we pecifically a k that the 

_ dmini trator e....Jabli h a rule which will make it nece ary for an3~ 

con ·ern de irina to undertake the manufacture of ~heet teel farm 

equipment to how a nece ity for uch increa e in productive capacity or that the product he intend to manufacture will better 

... erve the public intere t than the sheet-steel equipment now available. 

NEW RULE 

In ubmitting above trade practice rule for approval, the Sheet 

teel Farm Equipment A ociation desire to be given the privilege 

of offering for approval in the future such additional rule as experience may prove desirable, or to amend or withdraw old rule 

which prove unworkable. 

Re pectfully ubmitted for the Sheet Steel Farm Equipment 

Indu try. 

---, Chafr11wn 

---' , Executive "'ecretary, 

Executi e Com,1nitte of heet teel Farm, Equipnient As ociaNon. 

Dated at -------, -- day of --, 1933. 

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