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If your wishes are more complex, you may have your attorney communicate with the National Office for other suggested forms.








by James Gashel



An Investigation by New York State Senator Franz S. Leichter


by Tom Bozikis






by Mary Ellen Anderson



Copyright, National Federation of the Blind, Inc., 1979


Sightless people, with union help, are out to change a law that lets employers pay the handicapped less than the minimum wage.

[Reprinted with permission of U.S. News & World Report. Copyright, U.S. News & World Report. Inc., 1979. All rights reserved. This article appeared in the June 11, 1979 issue.]

America's blind citizens are rebelling against what they view as exploitation of low-wage handicapped workers by charity groups.

Many blind workers were prepared to press their complaint June 5, when the Labor Department scheduled hearings to review the wages paid by 3,800 "sheltered workshops" across the United States. These shops employ handicapped workers to make such items as potholders, brushes, soap and small electronic parts. Nearly 200 of the shops hire only the blind.

The 50,000-member National Federation of the Blind sought the Labor Department hearings to present evidence that blind workshops earn millions of dollars selling their products at competitive prices while paying workers as little as 58 cents an hour. The group asked the government to require that all employers pay blind workers no less than the minimum wage, currently $2.90 an hour.

Ever since the minimum-wage law was enacted in 1938, all employers have had an option to pay less than the minimum to workers with handicaps that might limit their productivity. This option is rarely used outside of sheltered workshops.

The federation's petition was prompted by widespread unrest among the more than 5,000 employes of blind workshops, some of whom are beginning to join unions. At the Cincinnati Lighthouse for the Blind, for example, administrators now are contesting a vote by workers who chose to be represented by the Teamsters.

James Gashel, an official of the National Federation of the Blind, says the blind workers are responding to a new emphasis on civil rights for people with all sorts of handicaps. Gashel notes: "These people in the workshops are simply saying, 'We have rights, too.'"

Although the current dispute involves only blind workers, experts predict that ultimately it may mean higher wages for all handicapped workers—including thousands employed by Goodwill Industries of America, Inc. Says Noel Price, executive director of National Industries for the Blind and its 134 workshops, "Can we say that we will pay blind workers the minimum wage and ignore the deaf and the mentally retarded?"


The dispute over wages for the blind also reflects a dramatic change in the status of handicapped people in the past few years. Once unable to get jobs outside special workshops, the handicapped now are being welcomed into industry at normal wages under new laws that prohibit discrimination.

Blind people have been the chief beneficiaries of this change. Most of them now work alongside sighted workers in private industry. And Gashel insists: "There's nothing about blindness that makes a worker so unproductive that he needs to be paid less than the minimum wage."

Sheltered-workshop operators meanwhile are suffering from their own identity crisis. Says Charles Fegan, executive director of the Columbia Lighthouse for the Blind in Washington, D.C.: "From being the good guys, we've suddenly become the bad guys."

Most of the workshops have been operating for decades as nonprofit charities, often in connection with a social-service agency. Their products are sold mostly to the federal government, although there are retail Lighthouse stores in some cities. During the year that ended Sept. 30, 1978, workshops operated by the National Industries for the Blind reported 125 million dollars in gross sales. Workers averaged $2.85 an hour, but many earned less than the $2.60 minimum wage then in force. Total payroll costs were less than 20 percent of sales, or below the average for labor-intensive industries.

The National Federation of the Blind contends that the money these workshops save under the minimum-wage exemption is being spent on huge salaries and plush offices for the supervisors, who are not blind. Moreover, the federation claims that the savings allow workshops to offer cut-rate prices to such large customers as Procter & Gamble and American Telephone & Telegraph Company.


Sheltered workshops also fail to encourage blind workers to seek jobs outside, according to the federation. A 1975 study showed that only 7 percent of all blind-workshop employes ever move into private industry.

Workshop operators defend their record on the ground that blind workers often refuse to go elsewhere. Price of National Industries says workshop profits barely cover the cost of extra services and supervision required by blind workers. A mandatory minimum wage, he adds, would force these workshops to lay off their least productive workers—the people who depend on their jobs the most.

"We don't oppose paying the minimum wage," says Price. "But we do oppose anything that would eliminate job opportunities for the blind."

The national federation insists that the workshops can be operated profitably at the minimum wage with better management. It cites as an example the Blind Industries & Services of Maryland, three sheltered workshops taken over in 1975 by a blind man with a proven talent for management. Employes of the Maryland workshops now average $3.19 an hour—plus vacation, sick leave and pension benefits.

Government officials appear to be listening to these workers' complaints with a sympathetic ear. Assistant Labor Secretary Donald Elisburg, who will decide the minimum-wage issue, says: "I don't see an end to the sheltered workshops—just a diminished role."

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On May 4, 1979 the U.S. Department of Labor announced that public hearings would be held in Washington to receive testimony from interested persons and organizations having views on the minimum wage petition filed on February 2, 1979 by NFB. Specifically, the Labor Department's announcement sought comment on the following issues: "whether the discontinuance of lower minimum wages for the blind and otherwise visually impaired individuals (1) will curtail their employment opportunities or (2) is not justified in light of their earning or productive capacity." The notice stated further that comments could be submitted by personal appearance at a June 5 hearing or in writing for the record. At this date (late June) the Labor Department is still receiving written comments, and it is expected that the cut-off date will be not much later than August 1st.

The rule-making petition we filed was outlined in the March Monitor. It represents the opening of yet another front in our long struggle to secure decent wages for blind persons, especially those who work in the sheltered workshops. What will come of these hearings is, of course, anybody's guess, and there are probably as many predictions as there are people to predict, but one thing is certain, we are forcing the issue, whether the shopkeepers like it or not.

From the beginning, the Fair Labor Standards Act has contained the exemption now found in Section 14(c) which permits any employer to obtain approval to pay subminimum wages to employees" whose earning or productive capacity is impaired by age or physical or mental deficiency or injury." Amendments to this Act in 1967 sought to limit the subminimum wages to no less than 50% of the minimum wage, but there are exemptions to this rule, for example, in the case of "work activity centers." The upshot of it all is that the law is quite complex and often misunderstood, even by people at the Department of Labor who are supposed to enforce it, not to mention by the shopworkers themselves who can easily be exploited, especially if they are unorganized.

Historically, overseeing Section 14(c) compliance has not been considered a priority function by the Department of Labor. Only 5% of all workshops (including both blind and general shops) are reviewed annually. The hearings on our minimum wage petition are the most sweeping survey of the subminimum wage question in nearly thirteen years, that is, since the Congress last amended the law. The petition, the Wall Street Journal articles, and follow-up investigations and reports by many local and national news organizations have sent the bureaucrats scurrying to cover themselves and to think up explanations for defending the current system, and all of this activity has also sent shock waves throughout the blindness establishment.

Speaking of which, there is the NAC/AFB/ACB/ALL Combine. Monitor readers will remember that these folks cut and ran during the 1978 Congressional hearings. The best they could do at the time was to send up one Col. John Hanger, representing National Industries for the Blind, and Milton Jahoda, known to one and all as Executive Director of the Cincinnati Association for the Blind. The principals of the Combine, however, failed to show. A few weeks later, in the company of their own kind, they passed a resolution on the minimum wage and the right to organize at the 1978 ALL National Delegate Assembly. The resolution said,

"Whereas, the Affiliated Leadership League of and for the Blind of America recognizes the fundamental principle of the right of all people to seek organized representation in relation to their employment and working conditions and,

"Whereas, in the exercising of such rights the individuals need for training, supportive service and the opportunity to accept work commensurate with their productivity must be taken into account and,

"Whereas, the U.S. Department of Labor recognizes that some individuals are so severely handicapped as to be unable to meet standard production rates and authorizes special individual wage certificates allowing those individuals to be employed and earn consistent with their capabilities and,

"Whereas, any requirement to pay wages to trainees and individuals in excess of their ability to produce would jeopardize the opportunity for rehabilitation services and employment of such individuals,

"Now therefore, be it resolved, that the Affiliated Leadership League of and for the Blind of America supports the concept that the National Labor Relations Board must recognize the unique nature of providing work opportunities for those with limited capabilities as part of the total rehabilitative process and exempt those individuals employed under U.S. Department of Labor certificates from N.L.R.B. jurisdiction."

This was quite a resolution, indeed, and especially so since ALL purports to operate on some sort of a consensus arrangement whereby if any of its members objects to a particular proposed position, the entire body will withhold making any statement whatsoever on one side or the other. Consider what this means with respect to the American Council of the Blind, for instance, which claims to be an organization representing blind people. We have often called it something else, more like a company union, a puppet of the agencies, and the ALL resolution is evidence enough for this conclusion.

But in case any doubt remains about ACB's sweetheart relationship with the agencies, the record is now clear on that, for who should appear at the Department of Labor hearings opposing minimum wage but one Durward K. McDaniel, representing ACB itself. Yes, I said, "opposing minimum wage"; this Mr. McDaniel, who warms so many chairs in so many boardrooms of so many agencies that he has even learned their line rather well. Listen and you will see what I mean. Here are a few of his statements made at the Labor Department hearing: "The ninety-nine workshops for the blind associated with the National Industries for the Blind in FY 1978 employed 5,124 legally blind persons who performed 3,177 man-years of work in direct production. These figures clearly indicate that a significant fraction of the 5,124 persons are part-time employees. Most of such part-lime employees received benefits as blind or disabled persons under Title II and/or Title XV1 of the Social Security Act. Title II blind beneficiaries may earn no more than $375 per month without affecting their benefit rights. Title XVI blind beneficiaries may earn a net of $85 per month because certain expenses are deductible in computing net earnings. However as a practical matter, such blind beneficiaries do limit their working periods in order to avoid the loss of benefits and the impairment of their eligibility for benefits. . . . Under the Fair Labor Standards Act employers paying subminimum wages must increase those wages pro rata in accordance with statutory increases in the minimum wage.

"It is estimated that approximately 40% of the blind persons employed in workshops receive the minimum wage or more and that approximately another 40% of such persons receive 75% of the minimum wage or more. In FY 1978 the average wage for the 5,124 blind employees aforementioned was $2.87 per hour. That average will increase as the minimum wage increases."

Now this sounds strangely like the rhetoric of National Industries for the Blind, and indeed, the last time we checked, Durward was serving on its Board. He has learned his lessons well, for according to the workshops, the blind don't really want minimum wage since they would lose their SSI, and blind people just love living on welfare, or so the shopkeepers say. But the fact is that Durward and his workshop cronies do not tell it like it is about SSI (whether by accident or design, we cannot say). The truth is that the law (Title XVI of the Social Security Act) allows earnings for blind persons to exceed the current minimum wage before SSI benefits are reduced or terminated. In fact, in most states (and we say it this way because state payments get involved) it is possible for an individual blind person to earn $600 per month and often more and still not lose much, if any, SSI, Durward's assertion to the contrary notwithstanding.

Actually Durward, while blissfully following the agency path, came up a little short on another of his facts when he tried to show that the Wall Street Journal was in error. He said: "With respect to petitioner's reliance upon statements published in the Wall Street Journal, we would point out that many of the statements made in that publication are contrary to information well known to the Department, to responsible organizations and to the blind workshop employees. To cite one example of error in the Wall Street Journal articles, profit-making companies do not receive credit for affirmative action under Sec. 503 of the Rehabilitation Act of 1973 when they contract with workshops for the performance of labor by blind or other handicapped persons. This prestigious publication has lent itself to petitioner's program of agitation without regard for the possible effect upon the employment of blind persons." The fact is that what the Journal said was correct, regardless of what Mr. McDaniel would like to think, competitive industry is permitted to and does use sheltered workshop employment as a means of complying with the affirmative action requirement of the Rehabilitation Act of 1973, claiming that the workshops are used as training for placement in the industry. This is legal and it is done.

I suppose it is really not fair to berate Durward for his behavior; probably we should not ridicule him for singing the song of the agencies, compassion may be more appropriate, for actually, he who pays the piper calls the tune, and yes, the piper's paymaster (the Washington representative of the American Foundation for the Blind) also testified, back-to-back with Durward, opposing minimum wage for the blind. This was to be expected; sooner or later AFB would have to come out of the closet. After all, the "field," as they like to call work with the blind, is now in serious trouble, and AFB styles itself a "service to the field," but certainly not to the blind.

Naturally there were some other agencies and their associations who appeared to testify against the petition, such as Goodwill Industries of America, National Association for Retarded Citizens, the Association of Rehabilitation Facilities, not to mention the Chicago Lighthouse for the Blind and the Cincinnati Association for the Blind. The formal proceeding itself lasted nearly three days. The NFB testimony will appear in full elsewhere in this issue. Also testifying in support of the petition were Rami Rabby (from his perspective as a management expert, specializing in wage and salary administration and affirmative action). Gene Raschi (President of the NFB Sheltered Shopworkers Division), Margaret White and Roy Smith (two shopworkers at the Cincinnati Association), Ralph Sanders (in his capacity as President of Blind Industries and Services of Maryland), Bob Sibley (Director of Mississippi Industries for the Blind), and E. U. Parker, who said he just wanted to speak out as a private citizen. Congressman Raymond Lederer from Pennsylvania also made a personal appearance in support of the petition as did staff members for Congressman David Bowen and Congresswoman Barbara Mikulski. In all, seventeen members of the House and Senate filed statements in support of our minimum wage petition, and none went on record opposing it. So all in all, we made a pretty good account for ourselves.

An analysis of the written comments received at the Department of Labor by June 19 is also rather enlightening. On balance there were probably about an equal number taking either side of the question, but then one must analyze the source. Almost without exception, those writing to oppose the petition represent an agency, usually a sheltered workshop, and conversely, almost without exception, those who support the petition are writing as private citizens, many of them blind, some who work in workshops on subminimum wages; a few are sighted persons outraged at what they regard as exploitation of the blind.

In this connection, the comment of the Institute for Public Representation of Georgetown University Law Center in Washington, D.C. is worth noting. The institute said: "The Institute endorses the National Federation of the Blind's ("NFB") petition seeking amendments to 29 C.F.R. Sections 524 and 525 disallowing issuance of subminimum wage certificates for blind or otherwise visually handicapped workers in sheltered workshops and in competitive employment. The Institute endorses the NFB's position of providing the full minimum wage to visually impaired workers and further agrees with the NFB's suppositions that provision of a full minimum wage is not only justified in light of data reflecting visually impaired workers' earning or productive capacity but will also not curtail their employment opportunities. Large membership organizations like the NFB are in the best position to know whether a full minimum wage would tend to curtail blind workers' employment opportunities. Moreover, as the Wall Street Journal article, which NFB cites, indicates, even with payment of a full minimum wage, workshops could continue to make a profit."

The process of evaluating the data and comments received at the Department of Labor is apt to be a lengthy one, and there are likely to be conflicting conclusions, depending on what level in the bureaucracy you talk to, but in the end there will come a moment of truth—a decision will be made. It is too early to say what the final outcome will be, but most people believe that conditions and rates of pay in the sheltered workshops will not be like they were in the old days before the public, the press, and the Department of Labor began to scrutinize the shops more closely than ever before.

We conclude with two letters, the first from a sighted Federationist in Chicago and the second from someone who just decided to write. Both of these show that there is a new mood abroad in the land—people are at last hearing our cry, and many will step forward to join us on the barricades; may all of us work to see that there will be many thousands more.

"Dear Administrator, Department of Labor:

"I believe there are soon to be hearings on the minimum wage to be paid to blind workers in sheltered workshops.

"I am sighted and have been a volunteer reader and recorder for the blind for many years. I am not affiliated with any agency or workshop. I have been on the picket line with blind workers. I know their grievances, their low pay, their discrimination and their being denied the rights to organize, to decent pay, to protection, and to security which other workers enjoy.

"James Gashel in Washington is the spokesman for the National Federation of the Blind (N.F.B.) ... He speaks for thousands and thousands of blind workers. He knows of conditions and pay in Mississippi, Ohio, California, Illinois and wherever blind workers are employed.

"I understand that James Kesteloot of the Chicago Lighthouse for the Blind spoke against this proposal to pay the minimum wage to blind workers. Mr. K is a staff member at the Chicago Lighthouse, he doesn't work in the shop. No blind worker is ever allowed to speak to visitors or asked to interview outsiders.

"Mr. K. was active in thwarting the efforts of blind workers in the Chicago Lighthouse to form a union; the vote failed by a small margin and five pro-union workers were dismissed.

"In California when blind workers went on strike, staff members took over. A blind worker had to do 120 units of work to get the best pay, a sighted staff worker (bookkeeper) did 75 units per hour and at rates paid the blind would have received $1.81 but because she was non-handicapped she was paid $9.81 per hour.

"The argument against paying higher wages is the old one, the shops can't afford it. This is false; with shoddy bookkeeping, inefficient audits, the figures can be produced to show losses.

"Some shops, one in Baltimore, do pay decent wages and remain solvent, so it can be done.

"Enclosed are two articles from the Wall Street Journal which give details. Please read them; they reveal much about the people who oppose the minimum wage to blind workers.


Gwendolyn Williams"

"To the Labor Department:

"As a Christian I am 100 percent for the blind and handicapped to receive the minimum wage and more if possible.

"Do unto others as you like them to do unto you.


Mrs. Virginia Story"

"Thank you"

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Editor's Note: In the March issue of the Monitor we reported the latest move in our effort to secure minimum wage for the blind—that is, the filing of a rule-making petition with the Secretary of Labor. Early in June, hearings were held before an administrative law judge at the Labor Department to receive public testimony on this issue. The following is the Federation's statement presented by James Gashel, Chief of the Washington office.

I appear here this morning as the representative of the petitioner in this matter, the National Federation of the Blind. We are asking the Secretary of Labor to amend the rules published at 14 CFR Parts 524 and 525 to effectuate a policy of limiting the granting of both special certificates (those which permit subminimum wages to be paid in regular workshops and training and evaluation programs under Parts 525.4 and 525.5) and individual certificates permitting subminimum wages under Parts 524.3 and 525.6. The limitation would be to discontinue issuing certificates of exemption from the minimum wage where employees or clients are blind or visually impaired. The petition identifies the specific sections of Parts 524 and 525 which could be amended to implement the limitation we propose.

Before I explain these specific contentions of the petition and outline the case in support of each, I will discuss briefly our role as petitioner. The National Federation of the Blind is a membership organization of 50,000. A small percentage of the members are sighted; most are blind. Most of us have our employment outside of work with the blind, and we give our time as volunteers because blind people need a representative voice wherever policies are being made which affect them. There is a fundamental distinction between the agencies for the blind and the blind who have organized together for common purpose and association. We represent the latter category, while groups such as the American Foundation for the Blind, the Industrial Home for the Blind, the Chicago Lighthouse for the Blind, the Cincinnati Association for the Blind, and National Industries for the Blind (to name a few) are of the former type.

It is also important to understand that the agencies for the blind have historically assumed the position of spokesman for the blind as well as service-provider. But speaking for the blind is not a legitimate function of an agency; at best, the agencies can only represent their own interests (which are certainly legitimate interests), but they may not coincide with the interests and aspirations of blind people. Only blind people who are left free to choose their own representatives through a democratic process can speak for themselves, and this is what we do.

The distinction I am drawing is the same as the difference between management and a labor union. Before the days of organized labor in this country, the only voice in American industry was that of management, and management always asserted that it knew what was good for the workers, and therefore, could speak for them. The advent of labor unions has changed all of this, but it didn't come without a struggle, and it didn't come without a few company unions, which tried their level best to look like real unions but did their level best to speak the company line. This whole process (with the exception of some of the violence, which we have so far avoided) is identical to our current struggle as blind people—we have the agencies and the industries which say they know what is good for us and want to speak for us, and we also have our company unions. You will hear from them, and there is no doubt that you will recognize them.

Many will try to change the focus of the questions we are dealing with in this hearing, but essentially the issues are labor-management in nature—primarily wages. Of course, the workshops and their associations will want the record to show that their operations are rehabilitative in nature and therapeutic (we will give full attention to this argument later on), but as we now begin to look at the issues in this petition, it is important to understand that we see the workshops as places where goods are produced for sale to public agencies or commercially, and we call this ordinary business activity, not therapy. If this premise is accepted—that is, that we are dealing with business—it follows that the production employees in the workshop enterprises should be entitled to the rights and benefits which other American workers are guaranteed and that includes at least minimum wage protection.

I begin with these background comments, because while the record of this hearing will show that there is opposition to changing the subminimum wage policy for blind people, the source of the opposition is just exactly what you would expect—management and their associations. After all, these people have a vested interest in maintaining the status quo. They have fought against the right of blind shopworkers to organize collective bargaining units under the authority of the National Labor Relations Act, and for many years they were successful, until recently when the National Labor Relations Board began to rule in favor of the shopworkers, and yet management is still contesting these rulings using every possible tactic to avoid good faith negotiations for suitable wages and working conditions. So we know this opposition well, and we also understand that historically it has had the ear of the Labor Department, where the voice of the shopworkers and their representatives has generally not been heard. The present action on this petition is a departure from the past, and to that extent, it is positive.


(1) Application of Section 14 (c) of the Fair Labor Standards Act to blind and visually impaired people is not necessary in order to prevent curtailment of employment opportunities for such individuals. The premise which underlies Section 14 (c) of the FLSA is that persons with handicaps may reasonably be expected to possess less capacity to produce goods as efficiently as the average American worker. From this premise it is reasoned that exemptions from the minimum wage should be permitted so that the minimum wage does not itself serve as a deterrent to employment for these presumably less productive workers.

This is an understandable position, and it may almost be considered humanitarian, but the question arises, where do you draw the line between providing workers with an advantage (that is, increasing their employment opportunities through permitting sub-minimum wages) or (on the other hand) taking unfair advantage of them by paying lower wages than they deserve? We contend that Parts 524 and 525 do not draw the line properly to protect productive blind workers while stimulating employment opportunities for others. The basis for this contention rests in three findings:

(a) For sheltered workshops for the blind in the National Industries for the Blind system, the percentage of workshop income paid out for labor costs (wages and fringe benefits for blind workers) is far below the percentage for labor costs in open industry, but where workshops for the blind guarantee at least minimum wage, the percentages equal out; hence, the minimum wage exemption prevents blind workers from receiving their fair share of workshop gross income. Labor statistics show that labor costs in labor-intensive industries run approximately 25% of gross income. The labor costs in the NIB system for fiscal 1978 were only 17.2%, and some of these shops had astonishingly low labor costs, such as the Jewish Guild for the Blind and the Industrial Home for the Blind, where the percentage paid out in wages and fringe benefits to blind workers hovered around 10% or less. Some shops, according to a New York state audit, were even less than this for 1977, so the point is that where workers are on subminimum wages, they do not receive their fair share of the workshop income.

(b) It is currently being demonstrated that workshops for the blind can successfully operate while guaranteeing minimum wage and not dismissing less productive workers; hence, blindness is not a factor which seriously impedes productivity. According to Labor Department data, at least fifteen workshops for the blind are currently not certificated for subminimum wages, suggesting that at least these shops pay all clients and employees at least minimum wage, and there are some certificated shops which rarely, if ever, pay wages below the minimum. This casts doubt on the validity of any regulation which permits subminimum wages to be paid to blind workers.

(c) Even under the present rules which make subminimum wages possible where there is no necessity for them, the majority of blind workers in the sheltered workshops earn more than the minimum wage, and the average wage for these employees exceeds the minimum. Approximately 60% of the blind workers in the NIB shops are paid above minimum wage, and during fiscal 1978, the average wage was approximately $2.90 per hour. This data points up that the blind shopworkers tend to defy the presumption of Section 14 (c) which predicts that they would be less productive than other workers.

(2) The productivity rating system which is used as the method for justifying Section 14 (c) certificates operates to the disadvantage of blind workers, since it fails to reveal their actual productive capacity. The central fallacy of the productivity-based system is that it fails to account for the elements in the work place which may impact positively or negatively on productivity, yet are not under the control of the workers. I refer specifically to factors such as production methods or equipment, which are functions of management.

This is of special importance to the blind because it has been proven in workshops for the blind that every worker can earn at least minimum wage if management institutes appropriate efficiency methods. Claude Whitehead, Coordinator, Training and Employment Services Policy Analysis, in the Department of Health, Education, and Welfare, in a July 7, 1978 letter to the Labor Standards Subcommittee, U.S. House of Representatives, points to the significance of management's role in worker productivity: "It has been my experience in operating, planning, and developing workshops over the past 26 years that the major factors in payment of better wages to handicapped workers are increased technology and business management and securing a continuous, adequate supply of suitable work. Workshops for the blind have clearly demonstrated that wages increase when there is adequate work, efficient management, and improved technology.

"Mary Jane Risch, Compliance Specialist with the Department of Labor, in a memorandum to Mr. Whitehead, lists some of the factors beyond the control of workers, which, nonetheless, lend to hold their wages down: "1) poor job lay-out resulting in a lot of wasted movement and excessive material handling; 2) the lack of appropriate jigs and fixtures—for example, counting the pieces instead of using a jig or weighing the pieces with a scale; 3) deliberate work-stretching by the workshop during periods when contracts are slow; 4) job designs that do not allow the client to work to his capacity—for example, assembly lines slowed down to the lowest common denominator; 5) boring, repetitive work such as counting plastic forks and spoons; 6) attitude on the part of clients that they won't make any more money than they do right now even if they work harder ... ; 7) IMPROPER WAGE PAYMENTS."

This list is not necessarily complete, but it does substantiate the point that productivity is substantially dependent on what management does or may fail to do. Given these facts, it is reasonable to assume that blind workers who are at the high end of the productive scale will benefit most from appropriate management efficiencies and that production can be increased enough to justify guaranteeing at least minimum wage. In short, what I am saying is that blind workers are, as a group, productive enough that it is reasonable for the Labor Department to require sufficient management improvements so that every one of them can be paid minimum wage or above. This is possible, just as it was possible to institute the minimum wage in the first place and to raise it from time to time.

(3) Operating margins are inconsistent with management's claimed need for subminimum wages. The term "operating margin" is used in this trade to refer to workshop profits, which can be found in most of the shops where, at the same time, the lowest wages are paid on certificates. Whenever these operating margins exist, it is standard procedure to use the funds left over to cover the costs of other programs in the agency which operates the workshop, and management justifies this by saying that, after all, the other services of the agency benefit the shopworkers, so it is fair for them to be paid for out of workshop proceeds.

The assertion that blind workers are not productive enough to earn the minimum wage pales in the face of the profit and loss statements of the workshops, such as the Cincinnati Association for the Blind, where in 1976 there was an operating margin of $144,651. According to its latest IRS filing, the Chicago Lighthouse for the Blind is doing even better than Cincinnati, showing a profit of nearly $200,000. In 1977 the Jewish Guild for the Blind in New York City had about $1,000,000 of income over expenses, yet blind people in the workshops were paid less than half of the minimum wage. Meanwhile, in 1978 the Industrial Home for the Blind (another New York City-based workshop system) had gross sales of $3,754,827 while paying blind workers as low as $.61 per hour and turning a profit of $2,413,827. Yet these are the very workshops which say they cannot afford to pay the minimum wage.

It is grossly unfair to shopworkers to deny them at least minimum wage while taking funds left over from the workshop operations to pay the costs of other agency programs. Often the shopworkers do not actually benefit from these other services, but even if all of them did, it would still not be equitable for shop income to be applied against the cost of services, since this practice amounts to unfair taxation. The Labor Department should not permit subminimum wages wherever there are operating margins.

(4) Subminimum wages cannot be justified on the basis that the workshops are engaged in training, rehabilitation, or therapy. The fiscal 1978 income data for National Industries for the Blind shops shows total gross sales of $123,728,044, an outstanding demonstration of productivity capacity by people in a therapeutic exercise. Clearly we are dealing with business activity here, and it is equally clear that the shops do not aim at preparing workers for employment on the outside. NIB data indicates a placement rate of about 6%, reflecting the number of blind shopworkers who move into competitive industry annually. Milton Jahoda, Executive Director of the Cincinnati Association for the Blind, expressed the view in a 1978 hearing that the placement rate of sheltered workshops for the blind should be zero, conceiving of the shops as places of employment, not training. The Industrial Home for the Blind apparently operates under the same concept, for they reported to a New York state senator that they had hardly placed any individuals in the last five years. So we are dealing with places of permanent employment, not training or apprenticeship programs which will offer an opportunity later on for substantially increased wages. It is a depressing thought to consider that there are capable blind workers going to their jobs, day after day, year after year, yet never taking home a paycheck equalling at least the minimum wage. Sometimes this lasts for twenty and thirty years, and it is morally wrong.

(5) Parts 524 and 525 are relatively complex, to achieve flexibility, but this also creates a confusing system which few of the workers ever understand, and this allows for unchecked manipulation by management. Mary Jane Risch, in her memorandum to Claude Whitehead, substantiates this, saying: "Last week I made a routine technical assistance visit to a WAC. The clients in that WAC work only two days per week. There were only two jobs in the shop. On one job the clients were not being paid anything at all (a serious violation) and on the other job they were paid on a 'piece rate' basis where the workshop had never performed time studies to establish what the piece rate should be (also a serious violation). They had also lost copies of the time studies performed on their previous silk-screening job (another violation). They did keep an accurate record of the hours worked by the clients."

Whitehead, himself, verifies the problem posed by the complex and flexible regulations, saying, "In our 1976 study, we found that more than one-fifth of the clients classified as regular employees were being paid illegally at less than the minimum rate specified in the FLSA. This may have been caused by lack of understanding of FLSA by the workshop administrators and/or may have resulted from lack of compliance enforcement by DOL (currently DOL investigates only 3 percent of the workshops annually). Equally important, DOL compliance investigators are not properly trained to investigate this unique population of employees."

The findings of Whitehead and Risch show how the present system is open to abuse, albeit unintentionally for the most part. We will probably never learn the total impact of this abuse, given the minimal number of investigations conducted annually, so our argument is that blind workers, who do not benefit from the flexibility of the present regulations, should be protected from the abuse which they tend to engender, or at least permit.

(6) Affirmative action and non-discrimination obligations for federal contractors and subcontractors and recipients of federal financial assistance are now mandated by law in the case of handicapped workers, and these are more positive and appropriate methods for assuring employment opportunities for blind persons than the continued use of Section 14 (c) subminimum wage certification in the case of these individuals. While affirmative action and non-discrimination are relatively new approaches on behalf of the disabled, they are especially beneficial to the blind who can work without limitation in most industrial settings, if given the opportunity to do so. Indeed, the problem is opportunity, and subminimum wages which mean low-cost blind labor, contribute to the problem, not to the solution. The Wall Street Journal article of January 24, 1979 entitled, "Sheltered Shops: Pay of the Blind Often Trails Minimum Wage at Charity Workrooms" cited several major corporations which were candidly taking advantage of the low-cost labor of the workshops for the blind, when the same blind people could be doing the same work on the regular payroll in the company plant. The recent investigation of New York state workshops for Stale Senator Franz S. Leichter confirmed the Journal's findings; no question about it, companies benefit from the low-cost blind labor, ignoring their affirmative action and non-discrimination obligations required under the Rehabilitation Act of 1973.

(7) Parts 524 and 525 are inconsistent with the work incentive provisions of our Social Security and public assistance legislation (Titles II and XVI of the Social Security Act) which apply uniquely to the blind. It is often said by management and their associations that blind recipients of Supplemental Security Income do not want to earn minimum wage for fear of losing benefits. This is untrue, for blind SSI recipients have a series of powerful work incentives available to them. In the first place, the determination of the disability of blindness is unrelated to income, hence, the substantial gainful activity rule does not apply, so earnings may go well above the current $290 per month limitation now placed on individuals with other disabilities. Secondly, blind workers may deduct from their gross wages any expenses necessary and attributable to their earnings, such as federal and state income taxes, PICA taxes, transportation to and from work, meals while away from home at work, payments for readers, and similar expenses, even the care of a guide dog. These expenses are subtracted from gross income so they do not count against the amount of SSI a blind person can receive. So these work incentives allow any blind person living anywhere in this country to work full-time at a pay rate well above the minimum wage and still not lose SSI eligibility on the basis of earnings.

The situation for blind people who benefit from Social Security Disability Insurance is not quite as favorable, but there too, there is a special higher amount which blind people can earn—$375 per month, which is slightly under the amount one would be paid working full-time at the minimum wage. There are also some other work incentive features (such as special eligibility rules for the blind) in the SSDI program.

Limiting wages through Section 14 (c) certificates denies blind workers the benefit of these work incentive features. The argument that blind people do not want to earn more begs the question since this is not a decision which can legitimately (or even legally, for that matter) be made by management. Blind people individually have the right to determine what they will earn, and when wages are held down so blind workers can stay on SSI, who is the ultimate beneficiary? It is the workshop, not the blind employee. SSI was meant for the blind, not for the workshops. The argument, therefore, that minimum wage will adversely affect the blind in terms of their SSI is not only fallacious, but also invalid, for it is none of the workshop's business what happens to our SSI.

(8) Although the arguments advanced so far primarily relate to the sheltered workshops, they apply with equal force to competitive industry where certificates of exemption are permitted under Part 524. In fact, there is very little controversy about this since regular industry has long since accepted the reality of the federal minimum wage. We have not been able to determine for certain, but we estimate that there are less than 1,000 persons certified for pay rates below minimum wage in competitive industry nationwide. This means that the impact of amending Part 524 as we propose would not impose a significant burden on industry, which could without difficulty, absorb any slight increase in labor costs.


This analysis reveals the major fallacies and weaknesses in the current Section 14 (c) certification system when it is applied to blind or visually impaired workers. Some will argue that you cannot single out the blind as called for in this petition, but the Labor Department's own studies show that the blind are singling themselves out as an especially productive category of workers, and it is now time for the regulations to be brought up to date with these findings. Others will contend that the blind are already paid equitably, but this will not be true even when the minimum wage guarantee is instituted, since few workers in this country begin production jobs at only the minimum wage. You will be told that the workshops will have to close their doors, leaving nothing for the blind people who presently have employment, but what about the substantial profit margins chalked up year after year by these workshops, and what about the tax advantages and other subsidies they receive?

The fact is that minimum wage for the blind is really not impossible to afford; the key factors are in the hands of management, not the workers. Today there are several workshops for the blind which demonstrate that efficient management, a suitable production line, and steady flow of contracts will easily yield enough income to pay everyone at least the minimum wage and more. The demonstrations of success exist, all we are asking is that at least they be recognized in order to provide the blind workers their fair share of income in the work force.

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An Investigation by New York State Senator Franz S. Leichter

Glenn F. von Nostitz
Legislative Counsel

Editor's Note: The hard work of our New York state affiliate continues to pay high dividends by uncovering the shameful practices of the NAC-accredited sheltered workshops in New York state. The following article was released in May by New York State Senator Franz S. Leichter. Keep in mind as you read these detailed findings that every workshop surveyed is accredited by NAC, so now there are six more answers when somebody asks you why NAC hurts blind people.

Workers in the seven federally certified workshops for the blind in New York State have become the victims of a serious pattern of exploitation. This is the major finding of an intense investigation of blind workshops by State Senator Franz S. Leichter, during which visits were made to several of the workshops and interviews were held with several hundred workshop operators, blind employees, private business people, and spokepersons for various blind organizations.

The investigation uncovered the following:

This report will look into all of these issues confronting blind workshops. It will first explain the federal law which permits payment of less than minimum wage. The report will then provide an in-depth analysis of six of the seven sheltered workshops for the blind in New York State, followed by a probe of the general issues raised above, taking into close account arguments raised by workshop administrators. Finally, it will discuss legislation that would put an end to the abuses, including an amendment to the State Labor Law requiring payment of minimum wage to blind workers.

We have personally inspected four of the seven federally certified blind workshops in New York State and have obtained information from six of the shops showing all or most of the following information:

—average hourly wages paid to blind workers

—aggregate of wages paid to blind workers last year

—aggregate of wages paid to staff members last year

—names of corporations with which the shops do business

—the dollar amount of sales to these corporations

—the dollar amount of sales to state and federal government

—the nature of the work done for commercial and government customers

—cost comparisons showing how much money businesses are saving by having work done by blind labor

—the amount of State subsidy the shops receive

—comments from shop administrators.


A provision of the Federal Fair Labor Standards Act (29 United States Code, Section 214) permits blind workshops to apply to the United States Labor Department for a certificate permitting payment of wages as low as one-half the minimum wage. The purpose of the federal statute is to allow blind workers to get training and rehabilitative help to enter the competitive labor market. Additionally, under regulations promulgated under the Act, even less than half the minimum wage may be paid to those workers whose productive capacity is deemed to be small; these workers need not be paid at all.

Under the federal regulations, the productivity of the blind workers is supposed to determine the amount of hourly wage received. Yet the method of determining this hourly pay rate varies from shop to shop, making it almost impossible to effectively monitor and police. One of the methods used to determine productivity is to "survey" productivity of sighted workers doing similar jobs in the private sector. Yet this method lacks the quality of being easily quantifiable, and, moreover, workers in private industry are often more productive because they operate new, efficient machinery which does not exist in the blind shops, or which is used only by sighted workers in the blind workshops. Thus, blind workers, operating with outmoded machinery and without the benefit of the imposition of other basic industrial efficiency techniques usually can be found to be less productive than their sighted counterparts.

In some of the shops, "productivity tests" are performed using staff members as a control group against which the blind worker is measured. Many blind clients complained about tests saying they are not administered uniformly and that certain advantages are given to the control group. A few blind clients complained that the test result figures are sometimes actually altered if it looks like a blind worker would produce more than the control group norm. They also complained that the tests use minimum wage as the ceiling so it is impossible to earn above that amount, and that the test results are usually interpreted so that even a worker who performs slightly below the control group norm would earn considerably below the minimum wage ceiling.

Our own observations of several shops in the State seem to bear out the complaints of the blind workers concerning the productivity tests. We observed blind workers performing their jobs quickly and apparently efficiently for extended periods of time. Most of them were earning under $2.00 per hour. And we observed that at the largest shop in the State, the Jewish Guild for the Blind in New York City, many workers were employed under special federal regulations allowing payment of no wage at all. From our observation, they appeared to be reasonably productive.

It seems clear from our investigations that the federal government is not properly monitoring the certified blind workshops. There are numerous allegations that the productivity tests provided for under the federal regulations are unfairly administered, and as will be shown later in this report, there are even more complaints that the rehabilitative ideal of the federal statute permitting payment of half the minimum wage has been lost.


Nearly all of the shops are operated by voluntary, non-profit corporations and associations. About eight percent of operating income of workshops comes from the voluntary sector. Workshops for the blind have a business income that constitutes about 75% of their total income, and government grants and reimbursements make up most of the rest of workshop income.

Jewish Guild for the Blind
15 West 65th Street and
111 Eighth Avenue
New York, New York
Robert Heimerdinger
Executive Director

This is the largest shop in the State in terms of the size of its budget. We visited both locations of the Jewish Guild for the Blind. Their 65th Street headquarters building was erected in 1971. This eleven-story structure is very plushly appointed, especially the top floor which is entirely devoted to the Executive Offices. Most of the building houses facilities for various blind services, including a mental health clinic, offices for social workers, and craft rooms. Located in two sub-basements are sheltered workshops where linens are sewn for the State Office of General Services for use in hospitals, and where various other small items such as headbands and belts are manufactured for the United States Defense Department.

From our inspection, the eleven above-ground stories appear to be severely under-utilized, although Executive Director Heimerdinger strongly stated they are heavily used. Nonetheless, a random mid-day tour through the building showed that most floors were totally devoid of people and even the elevators were empty on several trips up and down. The only large group of clients noted in the building were the blind workers concentrated in the sub-basement workshops.

The Jewish Guild also operates a large workshop at Eighth Avenue and 18th Street in the Port Authority Industrial Building, considered in the real estate business to be one of the best maintained and most expensive-renting industrial buildings in the City. It was once again noted that here, as at the 65th Street location, the administrative offices are large and impressively appointed with expensive furniture and original art objects. A large amount of floor space here is devoted to individual offices for staff members. All of the commercial work done by the Jewish Guild is performed at the Eighth Avenue location. By "commercial work" is meant manufacturing and packaging operations performed under contract with private corporations. In terms of gross annual sales for 1978, major commercial work done by the Jewish Guild for the Blind is as follows:

For the General Services Administration, Jewish Guild cut, stacked, and packed paper under a $640,000 contract.

A cost analysis of the largest commercial contract is disturbing. The Jewish Guild packed blister-sealed thermometers for Becton-Dickinson Corporation, at a selling price to the company of $143.63 per one thousand thermometers. Of this amount, only $15.82 went into the pockets of blind workers as the actual labor cost of blister-sealing the thermometers on a cardboard back. We called several independent packaging firms in the New York area for a labor cost comparison. They all indicated that the Jewish Guild price was extraordinarily low; the lowest labor cost for this particular operation we could find was $28.00 per thousand thermometers. It is clear that the workshop is severely underpricing itself and that Becton-Dickinson is saving many thousands of dollars while ostensibly "helping the blind."

Out of the $143.63 price paid by Becton-Dickinson, about $37.00 went to the cost of the plastic blister-sealing material and an additional $3.65 was paid to blind workers for packing the thermometers into cartons. Most of the rest of the selling cost went to "administrative burden."

Total salaries paid to blind workers for direct labor at the Jewish Guild in 1978 came to $293,819. Average hourly wages were as follows:

Blind: $2.30 per hour.
Blind, with other handicap: $2.09 per hour.
Blind (Work Activities Center, meaning blind workers whose productive capacity is deemed to be small): $1.15 per hour.
Blind, with other handicap, Work Activities Center: $ .80 per hour.

It is to be noted that all of the blind workers at the 65th Street location were in the Work Activities Center, meaning that they were being paid less than half the minimum wage. Yet, they managed to smoothly produce items for the Defense Department, such as headbands and belts, with a value of well over $1 million.

Wages paid to blind workers at the Jewish Guild were about 10 percent of total sales, an extraordinarily low figure when compared with private industry, where the percentage ranges around 25%.

If not to the blind workers, then where is all of the commercial and government revenue going? A large part of it goes to pay the staff, composed almost entirely of sighted workers. A flow chart depicting the management structure for only the Eighth Avenue location looks like it was meant for management of a Fortune 500 company. There is a Director of the Shop, a Mr. Donald Barcan, who earns "in the mid 30,000s," as well as numerous department managers, assistant department managers, production supervisors, clerks, and so on. There is a position entitled "Industrial Engineer," which has gone unfilled for several months according to Mr. Barcan. Also on the staff are two rehabilitation counselors, whom Mr. Barcan says are engaged primarily in work training and helping clients with work-related problems.

It was noted that altogether, there were at least 55 fulltime staff members for this location, only a few of whom were legally blind. When our visit was made to the Eighth Avenue shop, there were no more than 80 legally blind workers on the payroll. It was staled that this figure has never gone far beyond 125 at Eighth Avenue, or above 200 for both workshop locations. This translates into a ratio of about two staff members to one legally blind worker. This ratio is reflected in a comparison of salary figures; staff salaries for the shop amounted to $527,022, of which $442,636 was paid to sighted workers, more than twice the total paid to the blind, at an average rate of $7.02 an hour.

The cost of industrial supplies and materials for the workshops came to about $1.6 million last year. This still leaves several hundred thousand revenue dollars unaccounted for.

Some of these lost dollars go to help pay off the overhead for the rest of the organization. The 65th Street workshop is charged with $125,000 for occupying part of that building, or about 24% of the cost of occupying the entire building, even though they use only two sub-basement floors. (The bottom floors are larger Mr. Heimerdinger points out, but it was noted they are not that much larger than the upper floors and do not constitute 24% of the total space.) Also, the workshop at 65th Street picks up the tab for most of the depreciation for the entire building, as well as $217,000 or about 63% of the cost of expenses for various accounting and computer services used by the entire organization.

The Guild takes in about $11.2 million per year, half of it from state and federal programs, and in 1977, showed a profit of $1 million after expenses, including payment of about $3.9 million in staff salaries, topped by Mr. Heimerdinger's $50,000 a year. Much of the government money comes from the New York State Social Services Department, which in 1977, provided $502,670 as reimbursement for evaluation and training expenses. The State Education Department, under its Sheltered Employment Program, paid another $126,558. Under Medicaid, the State paid to the Guild $269,004. The New York State Department of Mental Hygiene made a contribution of $109,794 for maintenance of the hostel program. Even the City of New York helped out: the City Department of Mental Health provided $185,939.

The Jewish Guild for the Blind uses a large proportion of sighted workers, earning an aggregate of about $100,000 last year. The Guild's paper department, where looseleaf paper is cut and packed, is manned only 50% by legally blind workers, and in the sewing department, only 63% are blind. Federal regulations require that in order to remain certified, at least 75% of the workers of a sheltered shop must be legally blind. The Jewish Guild gets around this restriction by maintaining that some of their sighted workers are doing jobs that cannot be done by blind workers, so they, therefore, do not count against the 25% ceiling.

The large number of sighted workers gives some credence to the criticism that the shop does not really exist to rehabilitate blind workers but to run as a revenue producing business with blind workers on the payroll as cheap labor. Unfortunately, the effect of this heavy use of sighted workers for the more complex skilled jobs is that the sighted workers get all of the experience, leaving the blind worker behind—stacking boxes. Blind workers at one of the locations we visited said that they knew they could use some of the more complex equipment being operated by sighted workers, but that no one had ever bothered to train them.

Industrial Home for the Blind

57 Willoughby Street, Brooklyn,
1000 Atlantic Avenue, Brooklyn,
and 520 Gates Avenue, Brooklyn
P.O. Box 1002 Melville, Long Island
Joseph J Larkin,
Executive Director

Although in terms of physical plant overhead, the Industrial Home seems a more modest operation than the Jewish Guild, it, nevertheless, shares many of the same problems as its Manhattan neighbor, including low worker pay rates and poor management.

Various companies for which work is done at the Industrial Home include: Otis Elevator, Diagravure Film Manufacturing, Pfizer Chemical, Vogue Watch, Precision Assembly Corp., and Newman-Fine, Inc. Among the work done for these companies is the assembly of small electrical parts, manufacture of toilet cleaning brushes, the manufacture of industrial mops, and the manufacture of various apparel items for the Defense Department.

Industrial Home for the Blind's total commercial sales for 1978 came to $1.35 million. There were billings of $1.83 million to the federal government, and $564,000 to the State of New York. The total of all wages paid in the three workshops was $360,000, plus fringe benefits (included social security. Blue Cross) of $60,000. Total salaries paid to the staff managing the workshops was considerably larger: $619,000. Included in staff are all non-direct production personnel who run the shops, such as production superintendents, departmental supervisors, salesmen, and clerks.

The average hourly wage paid to legally blind workers at Industrial Home for the Blind was $1.65 per hour. The Gates Avenue location was the highest, at $2.24 an hour, and Atlantic Avenue paid an average of $1.98 an hour, with the exception of the Work Activities Center at $.61 an hour. The Melville location paid $.92 an hour, and was entirely manned by Work Activities Center participants.

One hundred twenty-five clients are listed as working in the three shops, with 48 at Gates Avenue, 41 at Atlantic Avenue (5 are in the Work Activities Center), and 26 at Melville. Yet a total of 73 persons are listed as being on the "staff" of the workshops, none of whom are rehabilitation or training personnel. Industrial Home for the Blind itself defines staff as all those employees of the workshops "other than blind persons performing direct labor operations."

Thus, out of total 1978 sales revenues of $3,754,827, Industrial Home for the Blind paid its legally blind workers only $360,000, which is an even lower proportion of the total revenues than the approximately 10 percent paid to workers at the Jewish Guild. $65,645 was paid out in salespeople's commissions (not reflected in shop salaries expense statement) and $107,666 for "outside sales commissions." Total expenses for the workshops in 1977 came to $1,341,000.

When questioned about their success in placing workers in outside industry. Industrial Home for the Blind officials responded that they had hardly placed any individuals in the last few years. They assert that most of their employees are not suitable for outside employment, yet careful observation of the work habits of those on the job during our tour showed men and women working non-stop, at a steady, quick pace. Indeed, some of the workers appeared highly skilled at operating various complex pieces of machinery, especially those who were making brushes. Yet, with about two exceptions, they were all earning near or well below the minimum wage. Workers who are not so productive are placed in the Work Activities Center where they get paid $.40 an hour. All of the work observed seemed to be rather monotonous, yet the workers appeared diligent and efficient.

Central Association for the Blind
301 Court Street, Utica, New York,
and 34 Main Street, Whitesboro, New York
Donald LoGuidice,
Executive Director.

The major commercial work done in Utica is packaging of small boxes containing various toiletry items which are distributed by airlines to passengers whose flights are delayed and who must be put up in hotels.

Following are the substantial commercial contracts for Central Association for the Blind:

Officials of the shop estimate the cost of packaging the kits at anywhere from four and one-half cents to eleven cents per kit, depending on the size of the unit involved. A major expansion of airlines packing in Utica is anticipated.

We called several independent packing companies in order to obtain a labor cost comparison. Of the four independent packing firms responding to our inquiry, the price for packing these same kits ranged from a low of twenty cents to a high of forty cents per box. It is clear that the airlines can realize a savings by having this work done by blind rather than sighted workers, and for this reason are expanding their use of blind workshops.

We were unable to obtain salary figures for the Central Association staff. However, average blind worker pay is $2.30 per hour, and the sheltered workshops reported expenses in 1977 of $359,034, of which nearly half were staff salaries.

From the State Education Department's Sheltered Workshop Program, Central Association received $19,340.65 in 1978. From the Department of Social Services, the organization received $32,608.

Total sales in 1977 came to $288,903 for this modest sized operation.

Blind Work Association
55 Washington Street
Binghamton, New York
James Zinck,
Managing Director.

This is the smallest of the federally certified blind workshops in the State. The major corporate clients in 1978 were:

For IBM, the blind workers salvaged chip board boxes and cable wires. The former activity required blocking out the print on the boxes with felt tip markers, removing old labels and attaching new black labels, as well as removing damaged tape and taping corners. The latter job consisted of removing damaged cable terminals, cutting wires to specified lengths and blocking out the former identification number and stamping a new number. Our investigation revealed that IBM is realizing a substantial savings in the approximate amount of $100,000 a year by having these boxes salvaged rather than discarded as was done previously. IBM pays the shop $132 per 1,000 boxes salvaged and $65 for each 1,000 cables salvaged. The cost of new boxes is $250 per thousand, so IBM gets to "help" blind workers while saving $100,000.

Blind Association of Western New York
1170 Main Street
Buffalo, New York
Stanley J. Grenn,
Executive Director.

The major commercial customers of this organization are:

Total business for the State of New York came to $307,000.

Other companies, with smaller contracts, include McDonalds Corp., Moog Corp., and Brimms.

The major work being done for these companies is the assembly of expandable file folders; also, cutting, rounding, fluting, perforating of paper and plastic products. Total wages paid to all workshop blind employees during 1978 came to $164,000, or about 15% of total shop revenues, a little bit better than most of the shops in the State. 80% of the workforce of Western New York's production staff were legally blind, 20% were sighted.

Department of Social Services reimbursement for evaluation and training fees came to $61,270 in 1977. State Education Department subsidies under the Sheltered Employment Program came to $21,157.

Association for the Blind
422 South Clinton Avenue
Rochester, New York
Judith D. Peters,
Executive Director

All of the work done by the Rochester Association for the Blind is for about 25 "local industries in our area." The Association did not wish to reveal the names of the corporations involved. The work done by the shop consists of salvage, sub-assembly, form tubing, packaging, mailings, and inspections. In February, 1979, 59 legally blind persons were working in the regular shop, and 22 were employed in the Work Activities Center.

In 1978, the shop revenues amounted to approximately $500,000, of which $150,000 went to client wage payments. The total agency budget last year was $1.3 million.


It is clear from the above descriptions of the New York State sheltered shops that there are some serious issues that must be addressed, including: low pay for productive work; excessive management staff size; underpricing and consequent unreasonably low cost to corporations doing business with shops; the use of low paid blind labor by the State of New York, itself; the alleged loss of Social Security benefits that would result from paying minimum wage. We will examine each of these issues in detail, taking into account comments and explanations proffered by workshop operators.

In spite of protestations of shop operators to the contrary, our investigation has revealed that wages are too low, and that many of the dire consequences of paying minimum wage predicted by shop operators would simply not materialize. Among the supposedly disastrous effects of paying minimum wage is that the shops would be forced out of the commercial market because they could not compete with private business. In this vein, Jewish Guild Director John Heimerdinger claims that most of the companies he is doing business with would go elsewhere if raises were given to his employees. (This is also a tacit admission that the main reason the companies do business with the shops is not "public interest", but because the cost is much lower.) Heimerdinger also asserts that it is better to give the blind something to do than to close the shops and leave them idle.

Loss of commercial contracts did not occur at the three blind workshops run by Maryland Blind Industries and Services in and around Baltimore, or at the Center for the Blind in Philadelphia when those shops were taken over by members of the National Federation of the Blind. The new shop administrators immediately started paying minimum wage and the same fringe benefits as staff members were receiving to their blind employees. Rather than lose contracts, the Maryland shops managed to more than double their annual commercial sales to $3 million. A similar experience was reported in Philadelphia.

Maryland Blind Industries and Services President Ralph Sanders explained to us how this was accomplished. Most sheltered facilities in the United States have no incentive to operate on sound business principles, he said. The shops have not created an environment where workers can be productive, so in Maryland, they created an industry environment, rather than a sheltered workshop environment. They did this by:

In testimony before a Congressional hearing last year, Hal Bleakley, Director of Philadelphia's Center for the Blind made the point that with adequate training, blind persons are just as productive, and sometimes even more productive than sighted workers. The equipment, management, and production problems of the certified workshops have nothing to do with the basic ability of the worker to be productive, Bleakley stated. Rather, they have to do with the ineffectiveness of the management of the shop.

The shop administrators often tend to understate the smallness of the wages paid to their employees for productive work. On a national level, gross commercial sales amounted to about $110 million. Yet, labor costs (wages and fringe benefits for blind workers) amounted to only $16 million, or 14.7 percent of gross sales, about half the average in private industry. This figure is reflected in the shops in New York State: Jewish Guild with about 11% of sale revenues going to wages, and Industrial Home for the Blind with 10%.

Opponents of minimum wage assert that it costs more to run a blind workshop than a private firm employing only sighted workers. Yet, as was revealed in the workshop description in this report, the shops receive subsidies of millions of dollars from the Department of Social Services and Education Department for evaluation and ongoing job training. There are also hundreds of thousands of dollars of private donations each year.

The shop administrators never mention that in private industry payment of minimum wage is rare. The American Management Association stated that in May 1977, the average wage for "Assembler I" was $4.43 an hour. This job description is similar to the lowest level assembly work done by blind workers in the regular shops and the Work Activities Centers. The starting wage for "Assembler I" is $3.55 an hour. Back in May 1977, the minimum wage was only $2.30 an hour. Probably the lowest paid non-handicapped workers in the country are those in the textile mills. Even they were paid an average of $3.41 an hour in 1976. Thus, even if blind wages are brought up to the minimum wage level, they will continue to be somewhat less than industry average, still allowing the shops to remain very competitive.

The ineffectiveness of the shop management to keep costs down is directly related to the problem of excessive size of the management staff. As can be amply seen from the descriptions of the various shops earlier in this report most of the shops in New York State pay their management staff much more, in aggregate, than they pay the blind workers themselves. In some instances, such as at the Jewish Guild for the Blind and the Industrial Home for the Blind, the staff make twice as much as the workers. There is no showing whatsoever that all of these personnel are needed to supervise the blind workers, who, from our observations, appear to have no problem working independently and without any more supervision than would be given to sighted workers.

The staffs of these organizations are filled with various production supervisors, assistant production supervisors, clerks, and so on, considerably out of proportion to the gross revenues received. All of these personnel, of course, earn more than the minimum wage. At the Jewish Guild for the Blind, their average hourly wage comes to $7.02 an hour for supervising workers making an average of $2.00 an hour.

Not only are the staff sizes excessive, but the staffs also do not include sufficient individuals whose function is rehabilitation and work training. The purpose of the shops is no longer to rehabilitate and place individuals in the competitive market.

A study performed three years ago by Greenleigh Associates, under contract with the Department of Health, Education and Welfare resulted in a 450 page report, entitled, "The Role of Sheltered Workshops in the Rehabilitation of the Severely Handicapped." The report compared the placement effort and record of blind workshops with workshops for individuals with other disabilities such as mental retardation. The report revealed that while 69% of all workshops have placement programs, only 19% of workshops for the blind reported having any such program. The report stated: "The visually impaired are substantially less likely than the average to receive any program except work hardening."

The rehabilitation counselors that do exist on the staffs of the workshops are there primarily to supervise work on the job, and not to offer assistance or training aimed at getting the blind person out of the shop. This is borne out by comments of blind workers themselves.

The Greenleigh-HEW report further revealed that workshops for the blind "offer the fewest rehabilitation programs and spend the least on professional staff" of all workshops. The report defines "professional staff" as one who works directly with clients in the area of testing, evaluating, teaching, therapy, and training, as opposed to non-professional staff members such as production managers, bookkeepers, and clerical help.

The Greenleigh-HEW study concludes: "The data show that large workshops for the blind have a lower placement rate than large workshops for those with disabilities other than blindness. It is interesting to note that the large workshops for the blind are also spending less money on placement and that they are allocating less of their professional staff costs to this function. It can be concluded from this that specific functional allocations of professional staff costs are related to results or outcome at the workshop level."

It is no surprise that 35% of the workshops for the blind polled in the Greenleigh-HEW study reported no referrals to private industry at all. Our own investigation of shops in New York State revealed that referrals to private industry are few and far between.

Officials at Industrial Home for the Blind defended their poor record of client placement, saying that their workers were simply not suited for work in the competitive market. This same remark was heard repeatedly at Central Association for the Blind in Utica. However, last year, at Congressional hearings held on the issue of changing the Fair Labor Standards Acts' rules on blind workshops, Joseph Wexelbaum. Chairman of the Affirmative Action Committee of the Office Products Manufacturers Association, discussed a model program they began in the New York area in which they aggressively sought out blind workers. Blind workshops in New York City were contacted for blind persons suitable for employment. The workshops were unable to come up with any names. The Association then contacted the Office of the Mayor of New York, which directed them to the Brooklyn Bureau of Community Services. They were promptly sent eight blind individuals who were "psychologically motivated" to work. Wexelbaum stated that these individuals "took no longer to train than the normal training program for sighted individuals" and are all now earning $3.25 an hour with no disciplinary or work attendance problems. The Association now employs 65 individuals in their program at minimum wage or higher.

The lack of emphasis on rehabilitation is also evidenced by the backgrounds of most of the workshop administrators. None of those we interviewed had had a background or training in rehabilitation. Nearly all had come from the management and executive ranks of various corporations, and a few had been in government employ.

The result of this non-existence of rehabilitation and training emphasis is reflected in figures showing that the average client of a workshop for the blind has been there for four years, as opposed to the average of one year for clients in workshops for the retarded and mentally ill.

Not only are large private corporations having work done at low cost by the blind in the sheltered workshops, but the State of New York, itself, has contracted with the sheltered workshops to do several million dollars worth of work, principally sewing of linens for use in hospitals around the State. At Manhattan's Jewish Guild, alone, over $1.5 million worth of work is done.

State law provides that the Office of General Services must purchase certain commodities from the workshops so long as their cost does not exceed market costs by more than 15%. Purchases are made through New York State Industries for the Blind, which has recently been involved in a scandal concerning the extravagance of Industries' top management. A New York State Audit revealed lavish spending on salaries, expensive restaurants, and on two Lincoln Continental Versailles with "moonroofs."

While major reforms are now being imposed on Industries for the Blind by the State, the practice of paying blind workers well below the minimum wage has not changed. And from our own observations, the workers in the sewing operations at Central Association in Utica and the Jewish Guild in Manhattan are the most productive and diligent of all. What is particularly disturbing is that all of the sewing machine operators at the Jewish Guild are part of the "Work Activities Center" earning an average of only $1.15 an hour.


Opponents to paying minimum wage in blind workshops argue that payment of minimum wage will raise incomes to a level where they will lose their Supplemental Security Income and Social Security Disability Benefit payments. This argument is untrue.

Under SSI, blind recipients are allowed to deduct from their gross wages all expenses attributable to their earnings. Among the deductions are federal, state, and local income taxes, F.I.C.A., transportation to and from work, meals away from home during working hours, special devices the blind use to perform a particular job, and most important of all, instruction in the use of a long cane or Braille. Even more significant, under SSI, the blind are not subjected to the "substantial gainful activity" test which denies benefits to others when their earnings exceed $290 a month.

Thus, many blind persons can earn up to $600 a month and still keep most of their SSI benefits. As for SSDI, the rules there are also much more liberal for blind individuals than for others.


Federally certified blind workshops in New York Slate no longer exist to rehabilitate and train blind persons for private employment. Their role now is to produce revenue, to keep staff members steadily employed, and to keep blind workers busy. This latter purpose was openly stated by all of the workshop directors as one of the main justifications for their existence. It was repeatedly stated that keeping blind workers busy in the shop is a lot better than letting them sit at home.

However, our study shows that blind workers can be paid the minimum wage and the serious consequences cited by workshop administrators will not come about if the following is done:

The Greenleigh-HEW study very well summed up the reasons why the certified shops are presently unable to pay the minimum wage. Their report suggested several hypotheses, among them that:

It would appear, in regard to the first Greenleigh-HEW hypothesis, that in spite of the large management structure, the shops are still incapable of properly pricing their work. Indeed, the Greenleigh-HEW study found that the sampled workshops were all unable to estimate operating income, let alone a subcategory such as business income, by an objective system such as is found in the recommended USERS (Uniform Socio-Economic Reporting System) system of financial reporting.


The most immediately effective antidote to the sickness affecting the sheltered workshops in New York would be to amend the State Labor Law to require payment of minimum wages to all blind workers, except those deemed to be "minimally productive." What an increase to minimum wage would mean is that the shops would be forced to economize in certain areas, such as staff salaries and expense accounts, and to institute the much needed efficiency reforms discussed above. This would provide more than enough revenue to pay the minimum wage.

Legally, the State is empowered to require payment of minimum wage in federally certified shops. 29 United States Code, Sec. 218, in fact, specifically provides that "no provision of this chapter . . . shall excuse noncompliance with any Federal or State law or municipal ordinance establishing a minimum wage higher than the minimum wage established under this chapter. ..." Additionally, recent case law, including the recent Doctors Hospital v. Silva Ricio, 558 F2d 619 (2nd Circuit, 1977) have found State regulations that are more liberal than the federal law not to be preempted by the federal statute.

In order to return the shops to their original function of rehabilitation and training of blind individuals, much better State regulation is needed. Although millions of State dollars are given to the shops each year, there has been practically no oversight of workshop operations. The entire responsibility has been handed over to the federal government with the result that abuses and quasi-legal practices of the sheltered shops continue.

The present Commission on the Blind and Visually Handicapped, which is a sub-agency of the Department of Social Services, has failed to exercise adequate oversight. The Commission has come under much criticism from the National Federation of the Blind's New York State Chapter and from investigations performed by other governmental agencies. The National Federation of the Blind proposes legislation removing the Commission from the jurisdiction of the Social Services Department and placing it directly under the Governor. Moreover, the present Commission also does not have any blind members. The National Federation of the Blind proposes that a majority of the board of the new Commission be legally blind.

Such a newly constituted Commission would be given the power to closely monitor the activities of the sheltered blind workshops and to issue sanctions against those shops that it deemed were not sufficiently emphasizing rehabilitation and training of the blind. Among possible sanctions would be an order stopping purchases by the State Office of General Services of articles produced by the shops and forfeiture of state tax exemptions.

It is time to give blind workers a decent living wage and to restructure the workshops so that blind clients receive real rehabilitative training. No longer should the shops serve as a cheap labor pool for private industry and the State, or as a source of secure jobs for former business executives.

The recommendations we have outlined will, if adopted, make major changes in the functioning of the sheltered workshops for the blind in New York State. It will bring them out of the 19th century and finally require them to treat productive blind workers the same as sighted workers in private industry.

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The quarterly Board Meeting of the Evansville Association for the Blind, a NAC-accredited agency located in Evansville, Indiana, was held April 17. As a most unusual change from its ordinary operating policy, the Evansville Association Board invited a featured speaker—one Fred McDonald. This is noteworthy in itself because Fred McDonald was, at one time, the Executive Director of the Chicago Lighthouse for the Blind, which fired several blind workers when they attempted to organize a union. Workers were being paid less than the minimum wage and were being forced to work under substandard working conditions. Some months ago Fred McDonald was released from his position as Executive Director of the Lighthouse for the Blind and is reported to have become a consultant for the American Foundation for the Blind.

Even if Fred McDonald's record for oppression of blind workers and his current association with the American Foundation are insufficient to stir interest, his message as a consultant is. His message to the Evansville Association is that the obituaries for sheltered workshops are now being written. At least one workshop has already closed he said. Another, Goodwill of Philadelphia, is about to close. There are ten major sheltered workshops on the verge of closing, and unless something is done, more are sure to follow.

The reasons for the shop closings are numerous. No one reason would be sufficient to drive them out of business, but all the problems at once will overwhelm shop management, and the shops will be forced to close. First, the National Federation of the Blind keeps making misguided attacks on the shops. Then this creates closer government scrutiny such as investigations into legal violations by the Labor Department. These investigations have been increasing in number and intensity lately. Then there is the minimum wage legislation in Congress. This legislation has brought pressure on the shops to increase the level of wages so as to avoid the charge that workers are being paid a mere pittance for their labor. The recent Wall Street Journal articles criticizing workshops' wage and employment practices and working conditions have distorted the image of workshops and haven't helped at all. And finally, the misguided efforts of the Teamsters to organize shops has caused considerable disruption and severe hardship. Furthermore, these conditions causing damage to the workshop establishment are not simply one-time occurrences, but are ongoing, and likely to intensify. If something does not change, the workshop concept as we know it will pass into history.

In presenting the potential destruction of the workshop system Fred McDonald admitted that occasionally the difficulties that workshops face are aggravated by poor management. However, the skill of the managers will not avail against the forces arrayed against the shops, and both the good and the bad will be swept into the dust bins and be only a memory.

The pitch used by Fred McDonald to drive his message home is highly emotional. He repeated for the Evansville Association Board his persecuted father scenario, which first emerged in the labor dispute surrounding the effort to organize the Chicago Lighthouse. Federationists will recall that Fred depicted himself as the hardworking executive, who, exhausted after a long and harrowing day at the office, returned home to be confronted by his own children with the question, "Daddy, why are you trying to hurt blind people?" The emotionalism of the appeal, along with its inaccuracies, illogic, and false assumptions, brand it as a scare tactic designed to drum up support for mismanaged workshops. The presentation explains away the views of the blind as misguided, and uninformed. It discounts the efforts of the Teamsters as similarly misguided, and misguided moreover by the misleading influence of the misguided blind. The publicity of the Wall Street Journal is distorted, and the future publicity it is likely to engender may be similarly distorted. The Labor Department, in a grandstanding effort to gain recognition in the light of the widespread criticism of the workshops has itself become unreasonably critical and picky in its investigations of labor violations. This is the character of the message brought to the Evansville Association by Fred McDonald, the consultant for the American Foundation for the Blind.

The solution proposed by Mr. McDonald is to slay alert, and remain informed. Be ready for the attacks that are sure to come. Mr. McDonald is assisting in this effort by conducting seminars throughout the country on the workshop problem and on current trends. To circumvent this threat to their organized existence the workshops must band together and demonstrate to the public that they are truly helping the blind. The workshops, unlike the blind, are well-informed, and have not been misguided or misled. Despite the discontent of some blind people, the workshops know best what their role should be in serving the blind.

Without dwelling on the details of this new service of the American Foundation for the Blind—that is the provision of seminars to teach agency personnel how to counter proposals of the blind workers that they be treated with dignity and respect and that their rights as workers be recognized—it seems strange that this service looks so very much like the old services of the American Foundation for the Blind. It looks, for example, like NAC, which has always believed and proclaimed with monotonous insistence that it knew better what was good for blind people than blind people did. Fred McDonald is intimately familiar with NAC. His former agency, The Chicago Lighthouse for the Blind espoused NAC, and his present agency. The American Foundation for the Blind, is NAC.

The methods of Mr. McDonald and NAC are also similar. They rely on inaccuracy or vague generality and ignore inconvenient facts. For example, the Labor Department discovers violations of the labor laws in more than fifty percent of all workshops investigated. Fred McDonald calls the investigations picky, overzealous attempts to gain recognition. He says that these investigations are driving the workshops out of business. One might wonder why he assumes that the workshops should be permitted to violate the laws of the United States. These shops already have special exemptions from the minimum wage protection of the Fair Labor Standards Act. The presumption and arrogance of the suggestion that the Labor Department should not investigate violations of the law and should permit indiscriminate violations of the labor laws characterizes the whole presentation. It is not only personnel of agencies for the blind who must be taught how to treat blind people by the American Foundation for the Blind, but also the Department of Labor, and the Congress as well. This is to say nothing of the blind, who must learn to accept the treatment meted out by the Foundation with humility and gratitude.

It has been demonstrated by several workshops for the blind that increased wages, increased worker security, and better working conditions do just the opposite of what Fred McDonald predicts. The increased staff morale and better management that such changes imply inevitably increase productivity in the shop. The blind are better off, the shops are better off, and the public benefits as well. The efforts of Fred McDonald and the American Foundation for the Blind are another in the series of transparent efforts to rally support around the banner of custodialism that has been so thoroughly discredited and so firmly thrust aside by the organized blind. The Foundation managers and Fred McDonald should come down from Olympus and look the truth in the eye. If they refuse to recognize reality, at least for them their own predictions will come true.

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Just months after the Washington state affiliate was reorganized, the new state leadership announced a program that will help educate employees of the hotel and airline industry across the country and, literally, around the world.

Affiliate President Scott H. Lewis designed a training and "sensitization" program aimed at employees whose jobs involve public contact.

"An integral part of the program," Lewis said, "involves work with the corporate personnel managers. We want to not only have existing employees better understand the normalcy of blind customers, but to build a better understanding of the blind man or woman as a capable employee."

The program already has two "takers," according to Lewis. Alaska Airlines and Western International Hotels are the premiere client corporations. Alaska Airlines is a regional Seattle-based air carrier and Western International is the nation's oldest luxury hotel chain. Western International has hotels in 19 U.S. cities and a dozen foreign countries.

"We want to polish our program and offer it to hotel and airline companies throughout the country," Lewis said, "I think that we have developed a program that is establishing itself at just the right time. The industries we are dealing with are delighted to begin a working relationship with the Federation."

Lewis has incorporated the film, "We Know Who We Are," into the 4-hour employee education presentation he has developed. A shorter one-hour version also uses the film, and is "less lecture and more discussion than the longer session," Lewis said.

"Considering the trouble blind guys have been having with airlines, I was really surprised to hear the level of acceptance we received at Alaska Airlines," he said. "There are a lot of misconceptions to be corrected, but that just means that there is a lot of progress we can make." The airline, he noted, was less than thrilled with AFB-backed material on blind air travelers.

The working relationship with Western International Hotels began over a year ago.

"There was an article in a restaurant trade magazine that described a truly terrible-sounding program instituted by the chain at the Century Plaza Hotel in Los Angeles. Braille markers were placed on such commonplace items as soap and showercaps, and a raised-line map was made available of the blind guest's room. The Braille Institute of LA was the chain's consultant. NFB groups in Los Angeles and Seattle expressed disgust with the plans and Lewis, accompanied by then-President Sue Ammeter and First Vice-President Ed Foscue met with hotel officials, including Western International President Harry Mullikin.

"We made some progress toward getting hotel managers together to see our film," relates Lewis, "but the thing died when Ammeter and Foscue started spending their time fighting the Federation. I picked up on the project after the reorganization and the hotel has been most anxious to go with a full program all along. I couldn't be happier about the outlook the hotel has. They've agreed to consult with us from now on, and we intend to help them all we can."

"I'd rather do something, and make a mistake, than do nothing at all," said Western International Hotels President Mullikin.

With the possibilities represented by the NFB's foray into corporate education, it looks like more executives than ever before will be given the opportunity to "do something"—and do it right.

Persons interested in the NFB Blindness Education Program sponsored by NFB's Washington State Affiliate can write to Scott H. Lewis, President; NFB Washington affiliate; P.O. Box 3001; Seattle, WA 98114.

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Had you been present at the semiannual convention of the California affiliate the weekend of April 27-29 in Los Angeles, you would have found it a very productive, worthwhile event. The purpose in mentioning this particular convention is that we are very pleased and proud to announce that it was our first as a new organized affiliate.

As you undoubtedly know, the "fall" of the old California affiliate took place last year; however, it did not take long to reassemble our loyal Federationists. The first weekend of November, James Gashel assisted in our work, and two weeks later we were honored to have Dr. Jernigan help with the final reorganizing. Now we are on our feet and are on the move!

We were delighted to have had Beth Bowen as our National Representative. We were also pleased to have had Scott Lewis, president of the other newly-reorganized affiliate—Washington State. Fred Schroeder, an ex-Californian now residing in Nebraska, added his usual sparkle to the proceedings. We appreciated the presence of representatives from the State Legislature and the State Department of Rehabilitation.

There were two panel discussions: "Social Services—An Update," and "Building and Strengthening an NFB Chapter." Some of the other agenda topics were: "The Blind as Mobility Instructors;" "Legislation Pertinent to the Blind;" "Using Public Relations on the State and Local Level;" "The Blind in Museum Work;" and "Rehabilitation Services." One of the highlights on the agenda was a presentation by Hazel tenBroek entitled "NFB Philosophy—Variations on a Theme."

Beth Bowen's spirited banquet address was received enthusiastically by a lively audience. That assemblage was probably the most vivacious banquet group ever.

President Sharon Gold not only understands the goals of the National Federation of the Blind but also has the integrity to carry them out, as was evident in her Presidential Report. Support for her leadership was demonstrated by the standing ovation she received as she concluded her statement.

Although the new affiliate is small in numbers, it contains those who gave over one-half the PAC plan contributions last year. At this meeting PAC plan contributions increased apace.

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On the weekend of April 28-29, Idahoans headed for Boise over mountains, across rivers and through the valleys of our state. We were very happy to have Joyce Scanlon with us as our NFB representative for the weekend. Ben Prows representing the reorganized NFB of Washington was with us and was a valuable addition to our convention. Several other visitors attended from the state of Washington.

Friday evening the board meeting was held and was followed by a meeting of the resolutions committee. Perhaps the most important resolution discussed and passed by this committee was one which proclaimed the NFB of Idaho's agreement with and support of the national board's actions concerning the states of California and Washington. This resolution was overwhelmingly passed by convention Saturday morning.

Saturday opened with greetings from President Norman Gardner and was followed by a good report by Joyce Scanlon on NFB national affairs from legislation to a progress report on our building in Baltimore. Other speakers throughout the day included William Hallock of the Idaho Oregon Lions Sight Conservation Foundation, Anthony DeSimone, Director of Rehabilitation Services Administration for Region X and Howard Barton, Administrator of the Idaho Commission for the Blind. We did pass a resolution commending the Commission for the Blind's cooperation with and responsiveness to our state organization.

In the afternoon we heard a panel of employers of blind persons, their expectation of these employees and their satisfaction with them. We were also addressed by our State Librarian on concerns with the Library for the Blind and Physically Handicapped in Idaho, by a Boise resource teacher, and by a representative from Mountain Bell discussing charges for directory assistance with an exemption for blind customers.

This full day was topped off by our banquet in the evening. We presented charters to our two new local chapters, and then listened to an address by Joyce Scanlon. It was well done and right to the point on some issues of concern to our members as well as to our out-of-state visitors.

On Sunday morning after the usual business and chapter reports, elections were held and officers elected as follows. President, Norm Gardner, First Vice President, Ruth Shove, Second Vice President, Mary Ellen Halverson, Secretary, Becky McKinley, and Treasurer, Harry Gawith.

One exciting motion we passed that morning was that the NFB of Idaho take along ten thousand dollars to Miami Beach for the National treasury. Top that Hawaii! We also made personal pledges and will send 50 percent of that amount to Box 11185. I believe that the actions of our convention this year show that the NFB spirit is strong in Idaho.

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The last weekend in April, 88 persons attended the NFB of South Dakota State convention, thereby doubling last year's participation. We were privileged to have Mrs. Diana McGeorge represent the National Board and give the keynote address, as well as discuss critical issues facing the NFB. Other speakers included representatives from the telephone company. Social Security, South Dakota School for the Visually Handicapped, and the Department of Rehabilitation Services to the Visually Impaired. Mr. Bill Dithmer, a visually impaired breeder of dogs from Wamblee, South Dakota, spoke to us about his career. Learning, awareness, and fun combined to make the 1979 South Dakota state convention the best ever.

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½ cup flour
1 cup sugar
2 cups milk
½ teaspoon salt
½ stick butter
2 teaspoons vanilla
4 eggs
1 cup coconut

Mix all ingredients in blender at high speed. Bake for 45 minutes at 350º.

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The Missouri affiliate of the National Federation of the Blind held their convention April 28 and 29, in Columbia, Missouri, with Ralph Sanders as a guest. Officers elected were: Gary Wunder, president; Tom Stevens, vice-president; Jana Sims, second vice-president; Dan Keller, recording secretary; Pauline Murphy, corresponding secretary; Nick Whitney, treasurer; Billy Weaver and Hershell Moore, members-at-large.

At their fourth anniversary meeting, the Prairie State Chapter of the NFB of Illinois elected the following officers: Allen Schaefer, president; Bill Isaacs, vice-president; John Salvatore, secretary; Mrs. Ruth Anne Schaefer, treasurer; Mrs. Ruth Bivens, Carl Miller, and Mrs. Evelyn Scanavino, board members.

On April 27, the Mutual Federation of the Blind (Cleveland, Ohio chapter of the NFB) held a testimonial dinner in honor of Glenn H. Hoffman of Lakewood, Ohio. Mr. Hoffman, who was born in 1889, has been very active in organizing, and in working for organizations of the blind for the past 70 years. The Mutual Federation of the Blind believes that he is the only living charter member of the National Federation of the Blind.

Present for the occasion were all the state and local officers of the NFB, along with many of Mr. Hoffman's long-time friends. Dr. Kenneth Jernigan sent a commendatory telegram, and Robert Eschbach, president of the NFB of Ohio, reviewed some of the important NFB accomplishments in which Mr. Hoffman has been involved. In turn, Mr. Hoffman reviewed a book which he is just completing telling of his life as a blind man and his involvement in the organizations of the blind.

Attention concerned Federationists! If you live in a city that has a population between 150,000 and 250,000, which has a mass transit system, the Lincoln Chapter's Committee on Transportation needs your assistance. We are developing a comparative study of transportation systems which we hope to use as the basis to push for better services. We are in need of schedules, annual reports, and information on the types of services offered and the cost of transportation per person. If you wish to contribute any information, please send it to: Craig Groff, 1035 S. 17th Street, Apartment C5, Lincoln, Nebraska 68508. Thank you very much.

Federationists can be proud of the wealth of material available from the National Office. Increasingly, we receive requests for our literature from libraries, public and private agencies, schools, colleges, and universities, and individuals unaffiliated with our movement. Truly, we have developed an unparalleled storehouse of information about blindness, and now with our new operation fully underway in Baltimore, we have updated and revised the order form. We have also added several new publications, some of which are listed below. Copies of the complete order form or any of the materials may be obtained from the National Office at 1800 Johnson Street, Baltimore, Maryland 21230. We have stocked up on many of the old standards, so all of us should see that these materials are circulated more than ever. The sale items listed below are especially good for libraries, schools, agencies, colleges, and universities. Payment for these publications should accompany the order, and quantity purchases can be arranged. Every Federationist should see that the agencies, schools, colleges, universities, and libraries in his or her area are well-stocked with these materials—they tell the story of blindness as it should be told, and they help spread the word of the independent blind who are carving out a better world for all blind persons. As a movement, our public information effort is something that everyone can take an equal part in, so let us all turn to, and see that the job gets done. The list which follows has been selected to highlight those publications which are most useful to libraries, institutions, and agencies as well as to the general public.

Publications for Parents and Educators of Blind Children

Your School Includes a Blind Student; (Print, $2.25)

A Resource Guide For Parents and Educators of Blind Children by Doris Willoughby; (Print, $4.95)

Section 504-related Publications

The Blind and Physically Handicapped in Competitive Employment: A Guide to Compliance; (Print, $2.25)

Section 504 and Blind Employees; A Guide To Reasonable Accommodation and an Illustrative List of Job Opportunities; (Print, $3.95)

Why Section 504; Discrimination Against the Blind in Employment, a Case Review; (Print, $4.95)

Miscellaneous Materials

Comments on Dog Guides; (Print) (This handy little leaflet will answer the standard inquiries and emphasize the usefulness of dog guides to those who prefer this method.)

I Am A Blind Mother Fighting to Keep My Children From Corruption (Print)

The Nation's Blind Can Help You Help Yourself; (Print) (This is an excellent detailed description of several plans for "deferred giving" through wills, trusts, etc. Broad distribution of this brochure will assist us in expanding the level of financial support for the Federation through such deferred giving arrangements.)

The Wall Street Journal Exposes the Sheltered Shop System; (Print)

An Open Letter to Directors of Agencies Serving the Blind Concerning NAC and Its Accreditation Practices; (Print) (This article pulls together and catalogues the many well-documented problems with NAC. It should be read by all Federationists as well as board members and directors of agencies.)

Separate Agencies for the Blind: Status Report 1979; (Print)

What is the NFB?; (Print) (This is an old standard, substantially revised and with a new look. Distribute these pamphlets liberally to one and all; they tell our story in brief, and they will help much to enlist the support of others.)

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