wish to indorse the Kendall bill, H. R. 6603, as meeting the requirements.

I wish also to indorse the Hogg bill, H. R. 1228, which guarantees to substitutes at least 30 hours' employment each week. This is a matter of simple justice to substitutes, who are required to report regularly at post offices, spending their time and money, often with most meager returns. I wish also to indorse the Kelly bill, H. R. 3087, granting vacations to substitutes, and I hope that you gentlemen will report these bills favorably and urge their enactment into law.

STATEMENT OF FRED D. SULLIVAN, CHAIRMAN FINANCE COMMITTEE, UNITED NATIONAL ASSOCIATION OF POST OFFICE CLERKS

Mr. SULLIVAN. Mr. Chairman and gentlemen of the committee, my name is Fred D. Sullivan, president of the Chicago branch of the United National Association of Post Office Clerks. The clerks of the Chicago post office, whom I have the honor to represent are vitally interested in the passage of a law granting a Saturday half holiday, The partial application of a Saturday short day, as it operates in our office, is, to say the least, quite unsatisfactory, particularly because of the inequality of the time granted to the employees of the various divisions and stations. This inequality is no doubt to some extent caused by local conditions in the various divisions and stations; however, it is thought that the reluctance of overcautious or too timid supervisors to take the responsibility is the chief reason why some clerks get little or no time off on Saturday. In Chicago our good postmaster, Arthur C. Lueder, strongly favors a liberal application of the order authorizing time off on Saturday, and yet, as might well be expected under the circumstances, the wide variance of time. granted to the employees emphasizes the necessity of legislation applying to all alike. We favor a Saturday half holiday law such as the Kendall bill, and believe that the time granted would be absorbed through increased production without any material cost to the Government. The passage of this bill would place post-office clerks on an equality with their neighbors and friends, most of whom enjoy the Saturday concession, and which will help toward rounding out a happy family life and will contribute toward making healthy and better post-office clerks.

I also wish to indorse H. R. 1228, which grants a weekly guarantee of 30 hours to substitutes in the Postal Service, and H. R. 3087, which grants a vacation to substitutes. The lot of a substitute in the Postal Service is at best a hard one. He is required to report at all hours with no assurance of employment, and continues on the substitute list for a long period of time with doubtful earnings. The passage of these bills would help to compensate those employees for the many adverse conditions under which they work, and I respectfully ask you gentlemen of the committee to favorably report these bills. I thank you.

STATEMENT OF W. M. COLLINS, PRESIDENT OF THE RAILWAY MAIL ASSOCIATION, WASHINGTON, D. C.

Mr. COLLINS. Mr. Chairman and members of the committee, I am not going into the bills under consideration in a general argument. I am interested in that part pertaining to the Railway Mail Service, and I will ask permission to submit a statement covering the effect of these bills upon the Railway Mail Service.

(The statement referred to is as follows:)

STATEMENT OF W. M. COLLINS, PRESIDENT RAILWAY MAIL ASSOCIATION ON H. R. 6603

H. R. 6603, a bill to provide a shorter workday on Saturday for postal employees includes employees of the Railway Mail Service. Conditions of employment in this branch of the Postal Service make it necessary to assign railway postal clerks to duties that are affected by train schedules, which make impossible the application of the principle of the shorter work day on Saturday by giving the actual relief on that calendar day. The employees in the railway mail service are divided into two main groups, those that perform their duties on moving trains, and those that are employed upon a daily basis. Those that are employed upon a daily basis would come within the general provisions of this bill and would receive the four hours relief on Saturdays. These are terminal railway postal clerks, transfer clerks, and railway postal clerks assigned to the offices of division superintendents and chief clerks. The service of both groups is governed by this provision of law:

"That service of clerks shall be based on an average of not exceeding 8 hours daily for 306 days per annum, including proper allowances for all service required on lay-off periods. Clerks required to perform service in excess of 8 hours daily, as herein provided, shall be paid in cash at the ammual rate of pay or granted compensatory time at their option for such overtime. Railway postal clerks assigned to terminal railway post offices and transfer offices and laborers in the Railway Mail Service shall be required to work not more than 8 hours a day, and that the 8 hours of service shall not extend over a longer period than 10 consecutive hours, and that in cases of emergency, or if the needs of the service require, they may be required to work in excess of 8 hours a day, and for such additional service they shall be paid in proportion to their salaries as fixed by law." (Act of Feb. 28, 1925.)

The greater part of the employees of this service are working on trains, performing distribution en route, between the principal mail centers and must necessarily continue with the train beyond the normal period of the workday. This has always been recognized and Congress has enacted laws defining the basis of the service to be rendered by this group assigned to trains. The service of these clerks must be upon an average basis and the law provides that they shall render the same annual service as other postal employees. It is simply a special act to cover special conditions. This act was first passed June 5, 1920, and reads:

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Service of clerks shall be based on an average of not exceeding 8 hours daily for 306 days per annum, including proper allowance for all service required on lay-off periods. Clerks required to perform service in excess of 8 hours daily, as herein provided, shall be paid in cash at the annual rate of pay or granted compensatory time at their option for such overtime." (Act of June 5, 1920.)

The act of February 28, 1925, was therefore a restatement of the act of June 5, 1920, in so far as clerks assigned to road duty were concerned.

This act provides for an average day of not to exceed 8 hours which 8-hour average must include all service required of the clerk on his regular lay-off periods which are rest periods, and time allowances for service already performed. Upon passage of said act, efforts were made by administrative officials to fix a detailed credit for "service required on lay-off periods' as provided by Post Office Department Circular Letter 1118, issued July 1, 1920.

CIRCULAR LETTER 1118

LAY-OFF PERIOD DUTIES

(d) Examinations, Schemes, Postal Laws and Regulations, and Instructions and Rulings on Space.

(e) Preparation of slips and labels.

(f) Making of trip report when not possible en route.

(g) Clerical work.

NOTE.-Allowances for service required on lay-off periods will be credited only to regular and substitute clerks in road assignments.

ADDITIONAL CREDITS

(h) Travel under orders of the department.

(i) Late trains.

(j) Extra duty.

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3. The time to be credited for each item under the heading Road Duty needs no explanation. Time credits for other items will be allowed as follows:

(A) EXAMINATIONS

Schemes.-Five minutes per card in each examination passed satisfactorily during the fiscal year or period under consideration.

NOTE. The number of cards on the examination on July 1, or when State sections are changed will be the number used in all computations for the fiscal year.

Postal Laws and Regulations.-Ten hours for each satisfactory examination. Instructions and Rulings on Space.-Ten hours for each satisfactory examination.

(B) PREPARATION OF SLIPS AND LABELS

In assignments where clerks are not required to use slips and labels, or where slips or labels are furnished by the department to clerks ready for their use, no credit will be allowed. As a guide to chief clerks in fixing credits for the preparation of slips and labels, the following basis may serve to establish a reasonable relation between the work involved and the credit to be allowed:

Letter-case labels.-Seven minutes per hundred.

Pouch or sack labels.-Twenty minutes per hundred.

Total credit allowed for this item, when reducing to a daily average, must not exceed 20 minutes per day on a 306-day per annum basis.

(C) TRIP REPORTS

As a guide for chief clerks in fixing the proper credit for making of trip reports, the following is a suggested basis:

Five minutes for each member of the crew up to and including four, and three minutes for each additional clerk until the maximum allowed for the train is reached.

The maximum credit for the making of a trip report will be 45 minutes, and will be given only in the important trains where more than one distributing car is in service and where the reporting of connections due to be made and received involves considerable work.

No allowance will be made where it is practicable to complete the trip report en route under average conditions. Where average conditions in the train involved permit of partial completion of the report en route, consideration should be given to this circumstance in fixing the credit for the trip.

(D) CLERICAL WORK

Under this item include all correction of schemes and schedules, book of instructions, instructions, and rulings on space, pouch records, monthly and special reports, registry records, and general correspondence and allow—

Not to exceed 15 minutes per day for clerk in charge, exclusive of registry records.

99147-30- -5

Not to exceed 20 minutes per day for clerk in charge, including registry records.

Not to exceed 10 minutes per day for distributors, exclusive of registry records. Not to exceed 15 minutes per day for distributors, including registry records. This was found to be impractical from an administrative viewpoint, and under date of May 12, 1921, an order was issued fixing a flat allowance of time to cover such duties. This order is the Circular Letter 1348, referred to in H. R. 6603. POST OFFICE DEPARTMENT, Washington, May 12, 1921.

Subject: Organization of lines.
Circular Letter No. 1348.

To all superintendents, Railway Mail Service:

Effective July 1, 1921, the organization of R. P. O. lines will be based on the following:

(1) Road service will consist of: (a) Advance distribution, including calling for registered mail. (b) Scheduled time on duty while train is in motion. (c) Unloading, including delivery of registered mail.

The minimum and maximum daily average hours of service on a 306-day basis will be as follows:

(2) The allowance for home duties will be 1 hour and 20 minutes for class B and 40 minutes for class A assignments.

(3) Lines now organized so as to require a daily average road service in excess of the maximum for the classification should be changed so as to come within the maximum.

(4) Lines now organized on a basis of less than the minimum will not be changed if, in the opinion of the division superintendent and the department, additional service is impracticable or would impose undue hardships. In all such cases, however, the report of the division superintendent should show in detail all of the factors such as the schedule of trains; lay-over at outward terminal; daily average delays; lay-off periods; study-scope and distribution assignments, and such other factors as may be pertinent in determining the consideration that should be given the assignment.

(5) In determining the daily average hours road service for an assignment, consideration should be given to the condition therein. It will be proper to allow a daily average near the minimum-the variation to be not more than 15 minutes above the minimum-when any one of the following conditions obtain:

(a) When the major portion of road service is performed between the hours of 6 p. m. and 6 a. m.

(b) Where the schedule is fast and there is no opportunity for advance work. (c) Where the duties of the assignment are sufficiently heavy to engage the attention of clerks over the full length of the run in both directions and where the study scope is exceptionally heavy.

(d) In assignments where there is but one crew and the service is not performed within a period of 10 hours.

(e) Where the daily average train delays is excessive.

No emergency or liability trips will be scheduled.

In assignments where the number of crews is four or more and the daily average hours of road service would be obviously too low if continued on a four or more crew basis throughout the year, it will be proper to reduce the organization by one crew during a portion of the year while annual vacations are being given. The period during which a less number of crews are scheduled should be shown on the organization sheet under head of remarks.

Additional scheduled service should be in the same line and in same trains as far as practicable.

(6) New organizations based on above instructions should be prepared and forwarded as early as practicable.

Form 5084, revised December 1, 1920, should be continued until present supply is exhausted, with following modifications:

Columns 11, 12, 13, 14, 15 eliminated.

Change number over column 16 to 11.

Change number over column 17 to 12.

The information as to delay in column 11 (new) should be based on 306 days. The first sentence in last paragraph under "General," on back of form, should be changed to read: "For each of these combinations show by name only one crew where the number of clerks in crew is in excess of four."

W. H. RIDDELL, General Superintendent.

That part of this circular letter pertaining to the proper allowance for duties on lay-off periods reads as follows:

"The allowance for home duties will be 1 hour and 20 minutes for class B and 40 minutes for class A assignments."

This allowance has been in effect since that date, and would be continued under the provisions of H. R. 6603. To illustrate how the present law operates, we have the average day of railway postal clerks assigned to road duty, divided as follows:

In the administration of the Railway Mail Service and actual operation of same we must be governed to a great extent by conditions affecting the operation of railroads in general. It is therefore somewhat technical to the uninformed, and this service has required various special acts which were necessary to fit conditions in the Railway Mail Service. This bill does not propose to give the employees of the Railway Mail Service anything but what is given to all postal employees, but in providing that the employees of the Railway Mail Service are to receive the same consideration we must also have a special provision defining how this consideration is to be given this group of employees. There is no question as to the intent of the bill in that all are treated alike. However, certain allegations have been made and certain estimates made as to the cost of administering and applying the 44 hour week bill to the Railway Mail Service. The Post Office Department has submitted estimates as to this cost, contending that the cost for the Railway Mail Service would be $4,500,000. I am vitally concerned in such contentions and beg leave to submit certain information which I believe will clearly prove the estimates of the Post Office Department erroneous.

In the Railway Mail Service we have two different laws governing the hours of duty of these employees. This is necessary, for the greater part of the Railway Mail Service employees work upon the railroad trains, and it is utterly impossible to administer an 8-hour day in that part of the service. Clerks can not work eight hours and then quit. They must follow the train, and that requires them to work anywhere from 10 to 18 consecutive hours. That part of our service therefore must be upon an average day, and such is so provided by law. The balance of the service is upon the regular 8-hour day provided for the other postal employees.

The apparent basis of estimates made by the Post Office Department is that every employee in the Railway Mail Service is to be relieved four hours each week and another employee placed in his position and paid a salary for that four hours. The department apparently uses in their cost estimates a much higher rate of pay for substitute service than that provided by law, but even if they gave every man four hours' relief each week and placed another man of the same grade in lieu of the man relieved in the assignment for that four