Document KJvEbmGVLX7jK5OJZ1JVB44qX
FILE NAME: National Safety Council (NSC)
DATE: 1937 Jan 11 DOC#: NSC315
DOCUM ENT DESCRIPTION: M em o from Donald Tulloch, Jrv to Licensees RE New Schedules & Classifications
TO LICENSEES:
DONALD TU LLO CH , JR.,
16th Floor, Inquirer Building Philadelphia, Penna. FEDF.TiAT.TRA
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General - New Schedules -'""Classifications
Opinions of Licensees with respect to revisions of schedules to conform to the Robinson-Patman Act indicate serious objections to the practical operations of the plan as proposed.
Further consultation leads to the belief that the following plan will meet the majority of the objections raised and still meet the approval of attorneys.
Plumbing, steamfitting and mill supply houses are the rehandlers of low pressure coverings and have in the past been considered wholesalers, chiefly for the reason that their sales are to contractors.
The plumber and steamfitter, however, is not actually in the contracting of covering, this being purely incidental to his regular business. Certainly he is not in the paint business simply because he paints a radiator, nor in the cement business because he pours a boiler foundation.
Actually the plumber-steamfitter is a consumer. The consumption of covering delivered to him in cartons actu ally changes its form, in passing thru his hands.
Hence, if the plumber-steamfitter truly is a consumer, the plumbing and steamfitting supply house actually functions for our industry merely as a retailer.
All classes of rehandlerst except the dual function rehandler will be sold as dealers. Dual function rehandlers who also function as plumbers or steamfitters, however, must be sold at the plumber-steamfitter level, in other words, as consumers..
Accounts sold on the consumer level may be rebated
to the dealer level on submission of affidavit to the effect
atshata
goods on dealer.
vfliich rebate
is
claimed
have
actually
been resold <-_
All dealers must be listed by licensees. Two
lists will be maintained: (1) Dealers who function solely in
reselling licensed materials to consumers; (2) Dealers who
perform the dual function - reselling and applying licensed
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Obtained.
No lr
Atty.
Federal Trade
. .terview
Each Licensee has the right to select the trade to whom he will sell. Lists as published will carry a code number indicating the licensee or licensees by whom the name was listed.
Additions to lists will be made at regular inter vals, but no sales to be made until listing has been published.
T. 1/11/37
f t s t x m .ir '.v'i. (M:
. Exhibit
Obtained U ' M 7.&> h-o7"/i^o.7 A-y.
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