Harry Targ
Historic
connections between organized labor and African Americans have been
problematic. During the period of modern
labor history, that is, from the formation of the CIO in the 1930s, to its
merger with the AFL in 1955, and into the present, labor's struggle against
racism has been mixed. On the one hand,
as Philip S. Foner describes it, the American labor movement throughout much of
its history has practiced racism in its internal organizational policies, in
its efforts to organize new workers under the banner of labor, and in regard to
its advocacy of political positions.
Writes Foner, “from the formation of the first trade unions in the 1790s
to the mid-1930s, the policy and practice of organized labor so far as Black
workers were concerned were largely those of outright exclusion or
segregation.”[1]
As a prominent institution in American life, perhaps it is no surprise that organized labor has reflected the currents of racism that run deep throughout American history. However, a close reading of labor history will also uncover significant exceptions to the rule. That is, various trade union confederations, such as the Knights of Labor in the 1880s, and the Congress of Industrial Organization (CIO) of the 1930s and 40s, reflected through words, and sometimes in deeds, the position articulated by Robert Baker in 1902, that the organization of workers should encompass “the cause of all humanity, regardless of race, color, or sex.” Said Baker: "The more organized labor champions the cause of all labor, unorganized as well as organized, Black as well as White, the greater will be the victories; the more lasting, the more permanent, the more beneficial and the more far-reaching will be its successes.”[2]
One of the most striking successes in the struggle against racism in the modern labor movement is a little studied labor union, the United Packinghouse Workers of America (UPWA), which formed as an organizing committee in 1937 and continued to represent packinghouse workers until its merger with the Amalgamated Meat Cutters in 1968. During its 30-years' existence UPWA struggled to organize and fairly represent workers in meat packing plants and collateral industries, fought to overcome racism within the union, and played a major role in building and supporting a burgeoning civil rights movement during the 1950s. In the words of Michael Goldfield: "The racial practices of the United Packinghouse Workers of America (UPWA) are especially inspiring."[3]
The UPWA story below is constructed largely from a set of 128 interviews with former members of the union, both from the rank and file and leadership, conducted by Halpern and Horwitz.[4] Three recently published books add to the literature on this progressive union, helping to create a history of a trade union led by a coalition of political leftists (many members of the Communist Party USA), liberals, and militant Black workers who stood for peace and social justice during difficult times in the United States, particularly after World War II.[5] In addition to the three new books and selections from the Halpern and Horwitz interviews, I will add a few insights gathered by my own interviews of three leaders of the UPWA.[6]
On Labor History
The industrial revolution in the period following the Civil War planted the seeds for a transformation of the workforce in the USA, shifting workers from farm to factory. With the emergence of modern manufacturing came increasing patterns of control and exploitation of workers. While many workers were initially skilled craftspersons who enjoyed autonomy and expertise, owners and managers of capital sought to increase control over the processes of work, especially in an effort to speed up production. Profits could be enhanced further by extending the length of work days as much as physical survival would allow. Of course, as capitalism grew and grew, profits also would be increased if wages were reduced as much as possible. Increasing managerial control of the work process, speeding up the pace of work, extending the work day, and cutting wages all stimulated the creation of labor movements to challenge capital's prerogatives.
In the 1880s a confederation of unions that embraced the skilled and unskilled, men and women, Black and White, organized as the Knights of Labor. While its history was short–lived, it fought for the eight-hour day and introduced into USA labor history a principle of inclusiveness that would flower and grow in the 1930s and beyond. Also in the 1880s, a trade union confederation called the American Federation of Labor formed, bringing together unions representing primarily skilled workers. Under the leadership of its first president, Samuel Gompers, the AFL built an organization that, despite ups and downs, survives to this day. Whereas the Knights practiced inclusiveness, the AFL as it unfolded gave primary support to the organization of skilled workers, and over time tilted toward segregation among affiliated unions, so that Black workers would be represented in totally Black unions. The AFL also accepted unions into the federation that constitutionally prohibited Black workers from membership.
From 1905 until World War I, a militant union, the Industrial Workers of the World, or Wobblies, organized hard rock miners, textile workers, and others. The IWW rejected political action, championing a syndicalist vision of a new world order, organized around worker control of the economic life of the country. Since the IWW rejected electoral and other more conventional politics, it was not involved in struggles around de-segregation and voting rights. However, the IWW championed the inclusiveness of all workers and rejected racism. Given their brand of revolutionary activity, Wobblies were hounded by the state and by vigilantes until, by the 1920s, they were virtually crushed.
After an interregnum of state repression, company unions, and company welfare schemes to keep workers from organizing, the 1930s saw a huge wave of political mobilization and labor organizing that led to the formation of the CIO. Some union leaders, led by John L. Lewis of the miners, withdrew from the AFL to form the CIO, because the former group refused to organize industrial, or so-called non-skilled, workers. Between 1935, at its founding, until 1940, the CIO unionized four million workers. Unions emerged in such industries as automobile manufacturing, electronics, steel, rubber, and meat packing. The great flurry of working-class mobilization was stimulated by the exigencies of the Great Depression, the exclusiveness of the AFL, and the groundbreaking work of communists and other leftists on the shop floors, who had worked for years to plant the seeds of the idea of industrial unionization. By 1955, over thirty percent of the American workforce was in unions. The AFL and CIO, the two major trade-union confederations, had over 100 member unions in them. Then the two confederations united, the legacy of which survives today as the AFL-CIO. This constituted the melding of the old craft unions founded before the 20th century with the newer industrial unions of the 1930s.
Meat Packing
The processing of meat was one of the earliest mass-production industries, developing a detailed division of labor that became a model for most subsequent manufacturing. The corralling, slaughtering, and dressing of meat products for shipment around the country became possible when the refrigerated railroad car was developed. By the turn of the century, meat was processed in huge centers in Chicago, Omaha, and Fort Worth, with smaller operations around Iowa and Minnesota. Meat packing plants were scattered throughout the South and Northeast as well. The meat processing center from the 1880s to the late 1950s was in Chicago. The stockyards, housing the ‘Big Four’ packers (Armour, Cudahy, Swift, and Wilson), employed thousands of workers. Because the work was so dangerous and unpleasant, it was largely carried out by the most marginalized sectors of the working class. First, this included primarily immigrants from eastern and southern Europe. During the great migrations from the South, both before and after World War I, Black workers gravitated to the packing plants, leaving behind their lives as sharecroppers.
Packinghouse workers, experiencing horrible working conditions and insufficient wages, sought to secure union recognition as the Amalgamated Meat Cutters. Two long and bloody strikes (1904 and 1921) were defeated by the companies. During both strikes, many African-American workers were temporarily employed to break the strikes. Since Black workers suffered from economic circumstances as desperate as those faced by the striking White workers, and since they were excluded generally from unions and consequently the benefits they would gain from unionization, these so-called ‘scab’ workers felt no loyalty to the strikers or the union. In the aftermath of the two defeats, hostility towards Black workers rose, and Black resentment of Whites increased as well. For years, remembrances of racism and scabbing impaired any effort to create a common front against the packers.
UPWA (CIO)
The atmosphere and historical circumstances changed in the 1930s. First, the depression hit working people very hard. Twenty-five percent of the work force was unemployed by 1933. Industries were working at 40 percent of capacity. In big cities, vibrant radical movements began to surface. Communists organized Unemployment Councils whose task it was to protect debtors from being evicted from their apartments. Also the Councils organized mass rallies and marches against unemployment and poverty and, on occasion, marched with throngs to city welfare departments demanding relief. Communists and other radicals were particularly active in Black communities. Also, the Communist Party mobilized mass campaigns to save the Scottsboro Boys who had been charged with raping two White women in Alabama, a charge that was clearly untrue. The mood of despair turned to militancy in cities and towns around the United States. Many Black citizens began to participate in the street militancy. These militants included those who were to work in the packinghouses. Inside the packing plants, Black workers had the most difficult and demeaning jobs and worked for lower wages. However, in terms of meat processing, Black workers were situated in strategic locations such as the killing floor. If they chose to stop working, the whole process of slaughtering and dressing meat would grind to a halt. Also in the major packing center, Chicago, the percentage of the work force that was Black was as much as 30 percent by the 1930s.
Both Black and White workers had come to the view that wages and working conditions would only improve when the work force became unionized. Also, Black and White workers both realized that successful unionization would not occur until and unless they combined to support unionization. This recognition, combined with the experience of working with radicals on community action, the clear role of communists in the effort to organize a packinghouse workers union, and the demonstrated work of the left in anti-racism campaigns nationally, all influenced the militant African Americans who assumed significant roles in organizing the union. White workers, often former union members from the days before World War I, and cognizant of the pragmatic necessity for solidarity, joined the struggle as well.
The first independent local of packinghouse workers was formed in Austin, Minnesota, by some old Wobblies in 1933. In 1934 there were general strikes of workers in various industries in San Francisco, Minneapolis, and Toledo, Ohio. In 1935, John L. Lewis, president of the United Mine Workers, walked out of the national convention of the AFL to form the CIO. Thus was launched the effort to organize unskilled industrial workers all across the industrial landscape. Also, in 1935, Congress passed the Wagner Act, which legalized the effort of workers to form unions. In this multidimensional context, Herb March, a communist organizer who had been working in Kansas City, arrived in Chicago to initiate the drive to organize the packing houses. In 1937, Black and White packinghouse workers with CIO approval formed the Packinghouse Workers Organizing Committee (PWOC) to begin the union building process.
The ‘Big Four’ meat-packing companies resisted the initial organizing efforts. Armour, the first target of the PWOC, resisted efforts to get a master agreement that would apply to all plants. Such a master agreement would institutionalize the union in the industry, an outcome that all the packing companies opposed. However, despite efforts of a discredited AFL union (the Amalgamated Meat Cutters) to counter PWOC presence in the Chicago Armour plant, and despite a pre-election visit to Chicago unions by the newly formed House Committee on Un-American Activities, the PWOC won majority support from workers for the new CIO union in 1939. Shortly thereafter, PWOC signed separate agreements for all Armour plants, a clear prelude to the master agreements the union sought. The initial accords, while not involving wage issues, did increase vacations, guaranteed at least 32 hours of work, and improved grievance procedures. Almost two years later, contract negotiations between Armour and the PWOC led to the signing of the industry's first master agreement in September, 1941. The accords included a ten-cent-an-hour wage increase. This was followed by agreements with Cudahy in November and Swift in April 1942. Finally, Wilson was forced to sign an agreement in March, 1943 by the National War Labor Board. Also in 1943, PWOC became the United Packinghouse Workers of America (UPWA). CIO militancy, the tidal wave of organizing throughout American industry, the particular role of White left activists and Black militants, and the emerging production needs brought by the onset of World War II all together stimulated the successes of unionization efforts in the meat packing industry.
While a wage-freeze agreement in support of the war effort was accepted by government, the corporate sector, and the leadership of the labor movement, PWOC was able to secure a variety of improvements in fringe benefits and working conditions during the war years. While labor, capital, and government all endorsed wage and price controls over the course of the war, government and capital did agree to not challenge the presence of unions in plants across the country (so-called ‘maintenance of membership’ agreements). However, as the war drew to a close, many unions in the CIO made demands for increases in wages. They claimed that prices in fact had increased by 45 percent during the war, while real wage increases were capped at 15 percent. While workers at the home front saved money, both because of much overtime and limits on commodities to purchase, their wages fell further and further behind prices and company profits. When corporations resisted pay hikes right after the war, unions in auto, steel, electronics, railroads, and meatpacking went on strike. The 1946 strike wave was the largest in U.S. history, affecting 4.6 million workers or 14.5 percent of the work force.
The strike in packing began on January 16, 1946. The next day, the Amalgamated Meat Cutters offered to settle in those plants in which they had locals with a 15-cents-an-hour raise. The packers refused, but a government fact-finding board was established to investigate the claims of the competing sides. Further, the Secretary of Labor ordered the meat-packing plants seized under provisions of the War Labor Disputes Act. After UPWA threatened not to return to work under the order, Secretary of Agriculture Clinton Anderson assured the union that he would urge adoption of any recommendations of the fact-finding board that were accepted by the packing companies’ unions. By March, a 16-cent hourly wage increase was recommended by the board and accepted by the packers and the unions. The Office of Price Administration granted the packers a raise in meat prices to compensate for the wage increases. Later in 1946, at its national convention, the UPWA elected Ralph Helstein as its new union president with the broad support of a ‘left-center’ coalition in the union. Over the course of the next several years, the UPWA leadership would tolerate Communist Party members and other radicals in the leadership and rank and file of the union, while walking a careful, straight line in support of mainstream CIO policies that became increasingly anti-communist.
The political stances of each of the ten UPWA districts varied, with radicals particularly popular in Chicago’s District One; District Three covering Iowa, Nebraska, and Colorado; and District Six in the Northeast. As the cold war and anti-communism heightened, some districts would pass resolutions supporting Henry Wallace or opposing USA foreign policy, while other districts would refrain from such positions or overtly oppose them. As packer-union struggles deepened in 1947 and 1948; as the coalition of manufacturers, Republicans, and Southern Democrats moved more actively against labor; and as the AMC sought to gain control of locals in packing plants, conflict between the left-center coalition and right-wingers known as the ‘CIO Caucus’ heated up dramatically in the UPWA. Many of the conflicts involved issues revolving around the cold war and anti-communism, and different conflicts emerged in the late 1940s around issues of racism in UPWA locals and how active UPWA should be in the struggle against racism in communities and the nation at large.
Anti-communism and racism
In 1948 UPWA again engaged in a general strike against the ‘Big Four’ resistance to wage increases. Because the USA cold war policy was developing, along with anti-communist zeal and the opposition to the campaign of progressive presidential candidate Henry Wallace, the level of support to strikers was not as strong. After nine weeks in which the meat packers held firm, injunctions were issued, police hounded strikers in various locales, and nonunion labor replaced striking workers, the UPWA called off the strike and returned to work. Six weeks after the strike, the UPWA met for the most contentious convention during the entire life of the organization.
In an intensely fought election for union leadership, president Helstein was reelected after a challenge from the CIO Caucus. The Caucus warmly endorsed the Truman presidential candidacy and his cold war foreign policy, favored purging the left from the union leadership, and generally took an anti-communist stance. Helstein's reelection allowed for the continuation of a left-center coalition that would more or less remain intact until the union merged with the AMC in 1968. This left-center leadership would remain critical of USA foreign policy, would endorse trade union militancy, would encourage rank-and-file political activity in communities, and would take a pro-active stance against racism in the union and the nation. Subsequent to the 1948 convention, and throughout the 1950s, UPWA would investigate racism in the union, establish Anti-Discrimination Committees at the national level of the union and in each local, would run workshops on racism in American life, and would fund and actively work for the burgeoning civil rights movement. UPWA would become a significant political force in those communities where it was strong (such as Chicago) and nationally.
To a considerable degree the transformation of the USA political economy was shaped by technological change. In the meatpacking industry, automation decreased the number of workers needed to produce the meat product and increased the possibility that production could be decentralized in hundreds of small-sized processing plants (where work forces are smaller, less organized, and more vulnerable). While UPWA was growing as a progressive political force in the USA in the 1950s, technological change was destroying the material base of the work force in the industry itself. Ultimately, with declining workers in the industry, declining UPWA membership, and continuing competition between UPWA and the old AMC, the leadership realized that it must consolidate to maintain any presence in the meatpacking industry. Consequently, in 1968 AMC and UPWA agreed to a merger. In 1978, the enlarged AMC merged with retail clerks into the current United Food and Commercial Workers (UFCW), a much larger union with a meat packing division.
Why Study the UPWA?
Even though the old UPWA no longer exists, its story is one of class struggle and a sustained struggle against racism. It is important to revisit this history to better understand the positive role of the labor movement in these struggles as well as the negatives and, perhaps, to learn lessons that might still have value to the role of a revitalized labor movement today.
Roger Horowitz writes that the UPWA was a union engaged in ‘social unionism’. By this he means a union engaged in activities addressing the needs of members as workers, as citizens of local communities, and finally as part of the working class in general. Most trade unions in the 20th century have practiced ‘business unionism’—engaging in bargaining and negotiation on behalf of workers' shop floor interests, but not engaging in broader political struggles. Concretely, this has meant that many trade unions have not engaged in the struggle against racism in their unions, communities, or society at large. As has been suggested above, the history of efforts to organize in meatpacking plants was fraught with defeat and bitter conflicts between White and Black workers. Strikes in 1904 and 1921 were lost because the ‘Big Four’ packers were able to use racism to divide packinghouse workers. Armed with this knowledge, Black and White militants struggled to overcome racism as they built the PWOC and later the UPWA. The 1943 constitution of the new union forbade racism in the union. Generally, from the outset of the CIO mass movement, the UPWA stood for racial equality in the union, but, as with many other unions, the UPWA did not actively engage in the fight against racism.
The failed 1948 strike against the ‘Big Four’ packers threatened to destroy the union. Large numbers of members were forced out, because they were fired by the packers. Factionalism surfaced, and during the 1948 convention an anti-communist slate of candidates ran for the various union offices. While the challenge to the incumbent leadership was defeated, president Helstein used the weakened condition of the union to launch an active anti-discrimination program that included efforts to purge union locals of racism and to commit each and every packinghouse local to the struggle for racial justice. From the late 1940s to the 1968 merger with the AMC, the UPWA distinguished itself in the struggle against racism and engaged in civil rights mass actions, even before the rise of the movement against segregation in Montgomery, Alabama. The movement in support of civil rights was driven by rank-and-file initiatives from militant Black and White workers in various locals of UPWA, and by the leadership of the international union itself. Not all members of the 100,000-member union embraced the civil rights agenda and, in fact, some workers from the South and Southwest particularly opposed the unions’ commitment to racial justice and integration of union and society. Over time, these elements were forced out of leadership positions in the union, leaving union members either civil rights activists or passive supporters of union efforts.
An early spark to the building of a commitment to the struggle against racism occurred when president Helstein hired sociologist John Hope to study race relations in the union. Hope found high levels of Black participation in union locals (for example Blacks were stewards in 83 percent of UPWA locals and 73 percent of locals had Blacks on executive boards). However, there were significant reflections of racism among UPWA members (30 percent objected to working with Blacks and 90 percent of southern Whites favored segregated eating facilities). Also, Blacks had a presence in significantly fewer job categories than Whites. As a result of Hope's findings, the UPWA at its 1950 convention initiated a broad-based program to expunge racism from union locals. An anti-discrimination department was established in the union at large, and anti-discrimination committees were established in every union local in the organization. These were not just symbolic gestures, but rather structures by which racism would be eliminated from the life of the union.
Union contracts were to prohibit any discrimination by companies, not only for employees, but for job applicants as well. Anti-discrimination conferences were held in the union on a periodic basis, and networking also occurred through national conventions and conferences of union members working for the same employers. Then UPWA strongly encouraged members to be active in the struggle against racism in their communities. Horowitz summarizes the full range of UPWA activities, from shop floor to political arena. In addition to integrating ‘lily-White departments’ on the shop floor and prohibiting discriminatory hiring practices, especially against Black women, “locals attacked discriminatory practices in their communities, primarily restrictions on Black access to bars, restaurants, and public facilities, as well as employment restrictions by local businesses. Finally, packinghouse workers consciously worked with and influenced community-based organizations, especially the NAACP."[7]
Black, White Unite and Fight
Several points can be made about the UPWA commitment to civil rights. First, as suggested above, the struggle to overcome the long history of racial strife in packinghouses was central to the organizing of the PWOC and UPWA since the 1930s. Second, Black militants and White radicals played a fundamental role in the creation of an integrated union. Third, a high percentage of the workforces in packing centers were Black workers, particularly in the industry's central facility in Chicago, where some 10,000 workers were employed. Fourth, UPWA constructed a union structure that gave real power to rank-and-file workers. Each department had at least one shop steward to represent the workers; and stewards, by virtue of their presence in the various job sites, were accountable to members. Also, many locals engaged in militant job actions when foremen tried to speedup production beyond what was called for in the contract, when particular workers experienced discrimination, or when other actions by management were seen as oppressive and discriminatory. Some locals were more militant than others, but the bottom-up structure of the union encouraged participation.
Fifth, president Helstein was fully committed to civil rights, as were most of the district directors representing regions around the country. Also, since the national leadership of the union refused to purge radicals from its ranks, UPWA had in its employ and as officers in union locals many radicals, including members of the Communist Party of the USA. Since they were among the strongest supporters of rank-and-file union militancy and civil rights, their presence reinforced other factors that stimulated UPWA's activism. Sixth, the most militant members of UPWA worked in plants in Chicago. Since Chicago alone had 10,000 UPWA members, and since a higher percentage of Blacks and leftists were in Chicago locals, that city's packinghouse workers set the tone for the organization.
As a result of these factors, therefore, the UPWA, or at least many locals, participated in active campaigns against racism in plants. They also fought for integrated neighborhoods. When Blacks moved into a public housing development in Trumball Park in the early 1950s, race riots occurred. UPWA members organized campaigns to force the city housing authority to open up public housing to Blacks and to protect them from racist responses. When hotels where UPWA meetings were to occur barred Blacks from housing, the union pulled out of the hotels in protest. When the Swift plant discriminated against hiring Black women, the Swift local and the Chicago district launched a public campaign and pressured government to end such practices.
Perhaps most importantly, UPWA was the first union to support the efforts of the newly formed Southern Christian Leadership Conference led by Dr. Martin Luther King, Jr. UPWA sent a check for $11,000 to SCLC during the Montgomery bus boycott, and leaders of the union marched with Dr. King from Selma to Montgomery; in Jackson, Mississippi; and participated in other mass actions. When Dr. King brought SCLC to Chicago to campaign for fair housing, the leadership of UPWA joined in. Horowitz argues that “UPWA's antidiscrimination program represented a significant expansion of social unionism” or activism beyond the shop floor. “Its aggressive policies contrasted starkly with the laxity of mainstream CIO organizations and represented an ‘opportunity found and kept’ by its Black members in a manner paralleled, to a far lesser extent, only by industrial unions expelled from the CIO."[8]
Conclusion
A reading of the volumes by Halpern and Horowitz, and the numerous interviews with former packinghouse workers that provide the data for their work, suggests that there is much of historic and contemporary significance in the UPWA. First, the UPWA, to a degree not achieved by many other unions in the CIO and AFL-CIO, created an integrated union in terms of leadership, policymaking, shopfloor protection of workers, and political program. Second, political radicals and Black militants provided impetus for the construction of an integrated, class-conscious trade union in the 1930s and 1940s. Third, the UPWA engaged in civil rights activities in various communities in the North and South, several years before the formation of the SCLC. Taken in conjunction with the efforts of other leftwing unions, it is fair to say that progressive sectors of the labor movement served as a major stimulus, inspiration, and resource for the rise of the civil rights movement in the 1950s and 1960s. While some sectors of the labor movement historically have impeded the path to racial justice, it is also important to point out that other sectors of the labor movement have played a critical role in whatever advances toward racial justice have been achieved.
Fourth,
the history of class struggle and the struggle for racial justice in fact go
hand in hand. The working class, by
virtue of its role in providing labor power for the construction of society,
and as the class that experiences the expropriation of the value that it
produces, is a leading force in movements of social change. African-American or woman workers, who often
belong to super exploited classes within the working class, constitute sectors
that have the possibility of seeing most clearly the exploitative nature of
society. Fifth, UPWA was to a
considerable degree a rank-and-file trade union. It practiced union democracy. Shop stewards, committees, job actions in the
production process, and picketing for civil rights all are expressions of the
will of the membership. All of these
activities were institutionalized and encouraged in the life of the union. Finally, the UPWA story is the story of the
success of the old leftwing slogan that still is relevant today: "Black, White,
Unite and Fight!"
Notes
[1] Philip S. Foner, Organized Labor and the Black Worker, 1619-1973 (International Publishers, 1976).
[2] Speech by Robert
Baker, presented to the Central Labor Union of Brooklyn, January 1902.
[3] Michael
Goldfield, The Color of Politics: Race and the Mainsprings of American
Politics (Ann Arbor; University of Michigan Press, 1997).
[4] Rick Halpern and
Roger Horowitz, Meatpackers: An Oral History of Black Packinghouse Workers
and Their Struggle for Race and Economic Equality (NY: Twayne Publishers,
1996).
[5] See Rick Halpern,
Down on the Killing floor: Black and White Workers in Chicago's
Packinghouses, 1904-54, (Champaign: University of Illinois Press, 1997);
Roger Horowitz, `Negro and White, Unite and Fight!':A Social History of
Industrial Unionism in Meatpacking, 1930-90 (Champaign: University of
Illinois, 1997); and Michael Goldfield, The Color of Politics: Race and the
Mainsprings of American Politics (Ann Arbor: University of Michigan Press,
1997).
[6] Harry Targ,
Interviews with Charles Hayes, Ralph Helstein, and Les Orear (Chicago, December
1982).
[7] Horowitz, Negro
and White, Unite and Fight!, p. 104.
[8] Ibid., p. 108.
