John Philips pleaded with his students yesterday "to open your minds and your hearts."
The students were federal regulation writers. Philips is an instructor in the plain-English workshop given monthly by the Federal Register, the daily compendium of federal regualtions.
Even before President Carter's order last week that executive agencies write in plain English, regulation writers had indicated a willingness to reform, or improve; there's a three-month waiting list to attend the four-day workshops.
Among the 27 students in the current class are:
A man and woman from HEW, who are rewriting a maze of regulations on Medicaid.
A man from the Coast Guard's office of boating safety, who is writing regulations on canoes and pyrotechnics.
A Nuclear Regulatory Commission employe who, among other things, helped write license exemptions for aircraft engines made of thoriated nickel parts.
A man who said he was working on GSA travel regulations, to which one instructor replied, "You have our sympathies.
And two representatives from the Federal Grain Inspection Service - one who said, "I don't have to write with them," and another who said, "I'm the one who writes them."
Fred J. Emergy, director of the Federal Register and force behind the plain-English workshops, began the program three years ago. Examples of horrible English had multiplied with the spiraling number of regulations that had to be printed. The figure reached more than 38,000 in 1976 and only about 1,000 fewer last year. That prompted Emery to remind each class that one of the first considerations before drafting a regulation is to question its need.
As an example, he read from the federal Register the regulations on behavior in the stable area at the Air Force Academy. They included warnings such as "no horse play" and "horses will be walked in the stable area at all times." Added Emery: "I keep worrying about the stamina of the horses."
Another example of useless regulation was noted in a separate interview by Wayne Granquist, an asssociate director of the Office of Management and Budget, which is charged with carrying out the president's regulations order.
Granquist said that on a fact-finding mission that took him to Kansas City he found a freight company operator with a basement filled with 1.6 million truckers' logs. They must be filed according to federal regulation. "And that was only six months' worth," said Granquist. "He had to rent a cave to store the stuff from the last three years."
"One of the hardest things to do is get rid of something already on the books," said Emergy, citing the regulation on maintenance checks of a certain pre-1917 engine that he said remained for years because no one would take the responsibility to get rid of it.
But if a regulation must be written, Philips urged the use of certain principles, such as avoiding redundancies. He came out against "any and all," "authorized and empowered," authorize and direct," sole and exclusive" and other government writer's staples.
Why do bureaucrats love the passive voice?" asked Philips. Then, pulling his suit coat up to cover his face, he said. "Because we want to be anonymous." Don't say, Each library book shall be covered . . . Say, the chief librarian shall cover . . . Philips came out in favor of action verbs, such as "consider," rather than "give consideration to."
Trying to involve the class in his discussion, Philips asked for characterizations of the legal jargon that often plagues government writing. Though some were lawyers, the students responded with such observations as "not clear, verbose, lengthy and archaic."
"yes, it tends to be archaic," Philips agreed.
A voice from the back said, "It's known to be archaic."
One student pointed out how difficult it was to get his superiors to agree on wording, one of the major problems faced by regulation writers. One group wants to say brief faced by regulation writers. "One group wants to say brief grounds for detail, and the other wants to say simple ground for denial, and I sit there with my pencil waiting for the winner."
More and more of the public is awaiting the outcome," said Philips, "Because more and more regulations are in areas that affect us." He told the class: "A lot of people read regulations or would read them if they could."
Carter's orderto make them easy to read, one student said, comes in response to the public's demand to understand what the government is saying.
This, of course, has not always been easy. One instructor said she was able to pass a state auto mechanics' qualification test that two auto mechanics failed because she could decipher the language; and that many inmates at one prison stopped disobeying rules when the rules were written so they could be understood.
With that, the instructors handed out all-too-typical examples of government prose to be edited by the students. Each class member would be awarded a certificate if, Philips said, "you successfully complete the course." That meant improving such passages as this classic:
"The initial and terminal points of the survey shall be accurately connected by course and distance to the nearest corner of the public-land surveys, unless that corner is more than six miles distant, in which case the connection shall be made to some prominent natural object or permanent monument, which can be readily recognized and recovered; in addition, the state number and plus distance to the point of intersection should be ascertained and noted, together with the course and distance along the section line to the nearest existing corner."
It was enough to make any writer repent.