Federal Trade Commission
Received Documents
P894219
Feb 1 1996
B18354900129
Secretary

WERNER CO.
93 Werner Road                Phone (412) 588-8600
Greenville, PA 16125-9499

February 1, 1996

Office of the Secretary
Federal Trade Commission
Room 159
Sixth and Pennsylvania Ave. N.W.
Washington, DC 20580

Re:  "Made in USA Policy Comment"
     FTC File No. P894219

Dear Sir or Madam:

     This letter represents our interest in participating in the public workshop on the above
captioned matter.  Werner is the largest manufacturer of ladders and climbing equipment in the
United States and sells its products through various distribution channels throughout the U.S. and
the world.  Because the safety and quality of ladders and other climbing products is crucial to the
U.S. consumer and because these products are widely used by the public in both commercial and
household applications, the Occupational Safety and Health Administration (OSHA) and the
American National Standard Institute (ANSI) have each set stringent standards for these
products.  At Werner, we take these safety and quality issues very seriously.  We believe
consumers have come to rely on these U.S. standards and look for the "Made in the USA" labels
when buying ladders and other climbing products.  Certainly in our industry, such a label implies
compliance with the OSHA and ANSI standards for ladders and climbing products.

     Our concern is that low-cost foreign manufacturers will produce ladders with the bare
minimum domestic content necessary to be entitled to claim their products are "Made in the
USA."  The foreign components that could be used in these ladders would typically be made in
countries with minimal or no manufacturing standards.  Lowering the domestic content to allow
for a significant percentage of foreign parts would, in our opinion, create safety and quality
problems for our industry.  Werner's position is that it is unfair to U.S. consumers to not have a
high domestic content in products that are represented as being made in the USA.

     The safety issue is not the only concern we have regarding a lower domestic content for
"Made in the USA" advertising.  A lower threshold we believe permits deceptive advertising due
to consumers' belief that "Made in the USA" implies that all or nearly all of the components and
labor are domestic.  If Werner is allowed to participate in the FTC workshop on this issue, we will
be able to expand on these comments and views.

     We look forward to being selected for this workshop and assisting the Federal Trade
Commission in this important endeavor.

                                   Sincerely,

                                   Donald M. Werner
                                   President