Colleges and universities across the nation this month are submitting comments on the draft collegiate code of conduct that seeks to eliminate "sweatshops" by establishing safe and humane working conditions in factories where college names and logos are applied to apparel.

Hunter Rawlings, president of Cornell University, one of 14 schools on the task force that developed the code, endorsed the efforts of the task force, saying the document represents a good beginning, but he added that it needs to be strengthened.

In a letter to licensing directors at the top 20 Cornell licensees, Rawlings wrote: "... the code must be a 'living document' that is subject to changes over time, but ... this comment period offers an opportunity to strengthen the code to require full public disclosure of factory locations where collegiate goods are manufactured and to ensure that an effective monitoring system is established to assure compliance."

Rawlings said he will ask the task force to improve the section of the code dealing with compliance and disclosure prior to including it in contracts between Cornell's licensing agent -- the Collegiate Licensing Co. (CLC) -- and Cornell licensees.

In an additional step, Rawlings said in his letter: "Since it may take some time for the CLC to include a code of conduct in new and renewal contracts, I ask that you and your subcontractors certify in writing [by April 30] that the spirit of the proposed code is being followed at all factories in the U.S. and overseas where products that bear the name of Cornell University are being produced." He added, "I trust that you share with us the importance of having a viable and enforceable code of conduct."

Rawlings' letter continued: "We at Cornell remain united in the pursuit of the task force objective --the improvement in working conditions for the men and women who produce the products that bear our name."

Last spring, Cornell became one of the first universities to declare that it would require manufacturers of Cornell memorabilia to follow a code of conduct. Since then, university administrators have participated in the CLC task force and in discussions on this subject with

students and other members of the Cornell community, the Ivy League Council of Presidents, the White House Apparel Industry Partnership and the Fair Labor Association, among others. On

Feb. 22, Students Against Sweatshops and the university co-sponsored a campus forum on the proposed code.