vided by the party furnishing the motor vehicles, whether the cars be obtained by bid or negotiation. Where an agency other than General Services procures vehicles, it would be obligated to obtain and convey this information promptly to the General Services Administrator.

TECHNICAL PROBLEMS IN BILL'S LANGUAGE

There are a number of technical problems relating to the language of the proposed bill of which you should be aware. As we noted above, the bill would require the furnishing of price information regarding items of motor vehicle safety equipment included in motor vehicles in compliance with regulations promulgated by the Administrator of General Services. However, by notice effective September 29, 1967, the Administrator revoked that portion of the Federal Property Management Regulations which had theretofore prescribed safety devices for automotive vehicles procured by the Government. The Administrator did so in recognition of the issuance by the Department of Transportation and the Department of Health, Education, and Welfare of standards for automotive vehicles. Although the Administrator in that same notice did reserve the right to issue additional motor vehicle standards not presently covered by the regulations and orders of those Departments, and has done so in certain instances, we have been given to understand that he does not presently require any specific safety features on passenger cars in excess of those prescribed by the Department of Transportation. Consequently, we wish to bring to your attention that there are no pending requirements for the inclusion of items of motor vehicle safety equipment on passenger vehicles imposed by regulations promulgated by the Administrator of General Services and, therefore, none for which the furnishing of any price information would be required under the proposed bill.

Additionally, even if the reference in the proposed bill to regulations promulgated by the Administrator were to be construed as referring to safety standards issued by the Secretary of Transportation under provisions of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1391, et seq.), a problem is presented. The proposed bill requires price information for items of motor vehicle safety equipment, while the Secretary is required to set his standards in terms of vehicle or equipment "performance" (15 U.S.C. 1391 (a)). This discrepancy in terminology poses difficult problems of application and interpretation both for the bidders and for the Government.

PRICE AND COST FACTORS ARE DIFFERENT

We also note that a purpose of the proposed bill is stated as requiring the disclosure of the "cost" of items of automotive safety equipment. However, the bill presently requires only that suppliers of motor vehicles indicate to General Services Administration the "price" which they are charging for each such item. Price and cost are quite distinct factors; a supplier may charge any price for an item of equipment regardless of the actual cost of its manufacture. Thus, in its present form, there can be no assurance that the proposed bill would achieve its stated purpose.

The principal effect of this bill would be upon the bidding and negotiating procedures followed by General Services Administration in the procurement of large numbers of motor vehicles for use by agencies of the United States. In these circumstances, we have deemed it appropriate to defer to the views of that agency regarding its desirability.

COST ANALYSIS SYSTEM UNDER CONSIDERATION

However, I would like to inform the subcommittee of present activities within the National Highway Safety Bureau to develop a capability for cost analysis for motor vehicle production.

We are convinced that a system analysis approach to cost is practical. This is an area in which the application of computer technology will be extremely helpful because of the large number of vehicle systems, components, variations in lead time, and other industrial engineering factors which must be considered.

We expect that it will be possible to express these results in averages, according to groups, such as large volume manufacturers, small volume manufacturers, and domestic and foreign manufacturers.

We are establishing within the Bureau's Motor Vehicle Safety Performance Service an Office of Product Cost and Leadtime Analysis to carry out these functions. This Office will determine whether proposed standards are reasonable, practicable, and appropriate for the particular type of motor vehicle or item of equipment for which they are prescribed.

The Office will evaluate cost, feasibility, and leadtime as required for the development, establishment, and enforcement of vehicle safety standards.

Apart from Bureau development in the field of cost analysis, it is our present plan to ask the manufacturers to supply economic data in addition to the engineering and technical data they now supply as part of their comments upon proposed new standards. Such data will assist us in determining the reasonableness and practicability of our proposals.

Mr. Chairman, we wish to thank you for this opportunity to appear before you today, and we stand ready to answer any questions to the best of our ability.

RIGHT TO KNOW PRICE DATA ACKNOWLEDGED

Senator RIBICOFF. Thank you very much. I will ask a few questions and so will Senator Hansen, and either you or Dr. Haddon can answer the questions if they are in your particular field.

Do you believe that the Government and the public have the right to know the price that they are paying for safety items in an automobile?

Mr. BRIDWELL. Yes. I think the Government and the public have the right to information in which they have the opportunity to evaluate the reasonableness of price in relation to safety and also for comparative shopping purposes.

Senator RIBICOFF. You do not want to add anything to that Dr. Haddon?

Do you believe that the automobile industry has the ability to supply to the Government and the public the price of safety standard items in automobiles?

INDUSTRY CAN SUPPLY NECESSARY PRICE INFORMATION

Mr. BRIDWELL. Let me label it in two ways, Senator, if I may. First an opinion, and then on the basis of what information we have which is sketchy.

My opinion is that they can. On the basis of the information available, I think that the manufacturers have responded specifically to letters signed jointly by Senators Mondale and Magnuson that they cannot furnish itemized or detailed prices on items of safety equipment or the cost of meeting a safety standard, but by the same token, I do note that they specifically attributed a price to one such standard. Senator RIBICOFF. Well, in other words, you are skeptical concerning the answer that the automobile manufacturers gave to Senators Magnuson and Mondale, because you believe it is within the competence and ability of the automobile industry to supply this information?

Mr. BRIDWELL. I think that is a fair statement, that I am skeptical without sufficient information to make an independent judgment.

Senator RIBICOFF. Well, would you not be rather surprised that such an efficient and able industry as the automobile industry would not know the price of every individual item from the smallest screw to the safety standards and equipment in an automobile?

Mr. BRIDWELL. I think the auto industry is a very efficient industry, Senator.

Senator RIBICOFF. Where do you believe the responsibility of the Government lies to obtain information concerning individual prices of safety equipment? What agency should have that?

DOT MUST CONSIDER PRICE FACTOR OF SAFETY STANDARDS

Mr. BRIDWELL. I am not sure that I am competent to answer that beyond stating to you that I think that we in the Department of Transportation have some responsibility because the Congress told us that in promulgating safety standards, we had to adopt them in the light of reasonableness, practicability, and appropriateness. So, a part of reasonableness and practicability also has to be the economic evaluation of a proposed standard.

Senator RIBICOFF. Do you have any concern that the recent price increase will deter members of the public from buying new automobiles and thus decrease the number of safer cars on the highways?

Mr. BRIDWELL. I do not believe that I really have a response to that, Senator. It is very speculative as to whether an incremental cost increase or an incremental price increase would deter a person from buying or alternatively, putting off a purchase for a year or two longer than they otherwise would, thereby not having the safety features on the vehicle they are using.

DOT MAKES BASIC ECONOMIC EVALUATION OF SAFETY ITEMS

Senator RIBICOFF. Now, while the automobile manufacturers have not supplied the public with the prices of the various safety standards, from your own research and your own knowledge in your Department, have you any idea concerning the price of various safety standard items that you have required?

Mr. BRIDWELL. Yes. we have ideas and, of course, we did some very rudimentary evaluation of this at the time that the safety standards were promulgated. However, we have stated, and state again, that at this point in time we do not have the capability, we do not have the resources and we do not have the specific data to make any kind of a sophisticated analysis and arrive at any definitive price or cost figure for a safety standard.

Senator RIBICOFF. In other words, of all the safety standards that you have promulgated, you could not give this subcommittee at this time a fairly accurate estimate of the cost of any particular item? The price of any particular item?

Mr. BRIDWELL. No, sir; we could not.

OBJECTIONS TO STANDARDS NOT BASED ON PRICE INCREASES

Senator RIBICOFF. Now, the report of the Senate Commerce Committee on the bill which became the Traffic Safety Act contained this paragraph, and I read it to you:

The Committee intends that safety shall be the overriding consideration in the issuance of standards under this bill. The Committee recognizes that the Secretary will necessarily consider reasonableness of cost, feasibility, and adequate lead-time.

Has the automobile industry as a whole or any individual manufacturer ever raised with you the question of cost or indicated that if a certain item were included, it would lead to a price increase, and in your preliminary discussions was this ever brought up to you

Mr. BRIDWELL. In the standards which were proposed and promulgated at the early part of last year, the manufacturers in their comments on the proposals raised many questions as to leadtime. To the best of our ability we have not been able to find anything in the records in which they challenged a standard on the basis that it would be excessively costly or would lead to substantial price increases to the

consumer.

PRICE OF SAFETY EQUIPMENT NEVER GIVEN DOT

Senator RIBICOFF. Well, have you yourself or your Department ever acquired from any manufacturer or from any other source the price of any safety items that you have required as standard?

Mr. BRIDWELL. We have not acquired price information from any manufacturer on a standard promulgated. Prior to the issuance of a standard some of our staff engineers who had the problem and the task of performing the evaluation, the analysis, I think gathered what

information they could at that time, but the answer to your specific question is "No."

Senator RIBICOFF. Do you receive or have you received any information from BLS concerning the price of these items?

Mr. BRIDWELL. Not to my knowledge, Senator.

RELATIONSHIP OF BLS TO AUTO INDUSTRY QUESTIONED

Senator RIBICOFF. Now, of course, I recognize the fact that if BLS has entered into an agreement with the automobile industry that it would be a breach of confidentiality if they disclosed it. But do you think it is proper for BLS to enter into such agreement or should BLS acquire this information independently so they would be freed from the restriction of making information like this available to the public and yourselves?

Mr. BRIDWELL. Let me answer the question, if I may, in three parts, Senator.

First, I do not believe that I am competent to make an evaluation of what kind of agreement the Bureau of Labor Statistics has to make in order to obtain the data that it needs for the Consumer Price Index or any of its other responsibilities.

The second point would be that the Bureau of Labor Statistics, I believe, necessarily must make its evaluation, its analysis, and arrive at its conclusions after the fact, after the fact meaning after the standard is implemented on the vehicle and a price is established.

The problem that we face from a standpoint of our responsibility is an evaluation of the economic consequences of a standard before it is promulgated.

Senator RIBICOFF. Well, how can you promulgate the economic consequences of a standard that you promulgate if you do not have the information concerning the price?"

Mr. BRIDWELL. Well, that is precisely what we are attempting to develop, Senator, through a series of research projects and then the implementation of this Office of Cost Analysis-Cost and Lead-Time Analysis, so that we will be able to independently form our own judgments as to the value or the economic cost of any proposed standard.

PRICE NOT A FACTOR IN PROMULGATING STANDARDS

Senator RIBICOFF. I know, but during-in other words, as you promulgate these standards or consider the standards, you do enter into lengthy discussions and comprehensive discussions with the industry and its representatives, do you not?

Mr. BRIDWELL. Yes, the process that is followed, Senator, is that we publish in the Federal Register a proposed standard on which we seek written comments.

These are supplied by the manufacturers as well as any other interested party and then subsequently technical meetings are held in which members of the staff and representatives of the manufacturers, and again any other interested parties, may participate in the discussions prior to the development and the promulgation of a final standard.