21)
Standards Association is an attempt to bring about greater uniform-
ity in the development of safety regulations by the various regulatory
trade associations, insurance companies and rating bureaus. The
desirability of cooperating in this movement was evident to the De-
partment whenever it endeavored to collect material for the develop-
ment of regulations on a particular subject. National codes are de-
veloped by the best minds in the country and the Department, there-
fore, has the opportunity of taking advantage of expert opinion, which
it could not do if it had to pay for such service.
An additional advantage to the Department in adopting the na-
tional codes as a basis for state codes, is that it simplifies inspection
work. The national codes are being used by national trade associa-
tions as standards to be used by their members in the manufacture
of their products. This means that machinery and equipment will be
sold direct to Pennsylvania industries in a form acceptable to the De-
partment making it unnecessary to issue orders for the purchasing of
this equipment. It will mean that in an industry, such as the con-
tracting industry, the members of which no longer confine themselves
to a particular locality in which to work but who go out for business
everywhere, can be assured that their equipment will be acceptable
wherever they go and that they will know and understand the rules
and regulations that they will be required to comply with. For these
and many reasons the Pennsylvania Department of Labor and Indus-
try has joined the ranks of other forward looking states and is using
national codes as the basis of the state regulations whenever this is
ossible.
° Whenever national codes are not used, the Research Section con-
ucts its own investigation and from the data collected prepares a
tentative draft of the proposed regulations. An advisory committee
from the industry to be affected by the regulation is appointed to
whom is referred this tentative draft. This committee composed of
:mployers, employes, technicians, and members of the Department,
ase this tentative draft as a basis for discussions and for preparation
of a new draft for presentation to the Department. One such advisory
committee is now cooperating with the Bureau in the development of
the new Fire and Panic Regulations. Clarence W. Brazer, President
of the Pennsylvania Institute of Architects, assisted in the formation
of this committee, which is composed of Irwin T. Catharine and George
I. Lovatt, both of Philadelphia; Julian Millard, Harrisburg; G. Wes-
ley Stickle, Erie; and Donald F. Innes, Wilkes-Barre.
From this point, the procedure in the development of regulations
is the same whether the national code plan or the state committee plan
ls used in preparation of the tentative draft. The draft of the regu-
lation is sent to the Industrial Board in order that it may hold public
hearings on the regulations to determine whether they shall be ap-
proved for promulgation. A copy is also sent to the Bureau of In-
spection for its eriticism from the viewpoint of their practical experi-
ence. The criticism received by the Industrial Board in this way is
reviewed by the Bureau of Industrial Standards, and a final draft of
the regulations prepared, which is again submitted to the Industrial
Board for final approval. Promulgation by the Secretary of Labor
and Industry immediately follows approval.
This outline of the procedure followed by the Bureau of Industrial
Standards in the development of regulations indicates the effort that