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I'lanniHL; and Staiulai J>
UN \LREPORT
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&EPA ECONOMIC IMPACT ANALYSIS OF
THE LEATHER TANNING AND
FINISHING OPERATIONS NESHAP
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TABLE OF CONTEXTS
Section Page
E\ecuti\ e Summarx i
1 Introduction 1
2 Industrx Profile 1
2.1 Production O\ erx ie\\ 2
2.2 Producers of Finished Leather Products 7
3 Economic Impacts 11
3 1 Summarx of Compliance Costs '. 11
3.2 Market Impacts 11
3.3 Small Entitx Screening Analxsis 12
4 Summarx 14
5 References 15
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard. 12th Floor
Chicago.lt. 60604-3590 *uir""*
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EXECUTIVE SUMMARY
The U.S. is a key pla\er in the \\orld market for leather goods. We are a top producer in
all facets of leather production, including:
• raising cattle, sheep, pigs, and other animals:
• tanning and finishing hides and skins: and
manufacture of finished leather goods.
The regulation de\ eloped b\ the EPA to reduce emissions of HAPs will impact 16
facilities in the leather tanning and finishing industn and are o\\ned by 14 parent companies.
The industn includes approximate!) 300 establishments in all. therefore, the affected producers
represent a ver\ small fraction of the leather tanning production in the U.S. The regulation is
expected to cost a total of S437.589 annualh. \\hich is 0.0014 percent of industn revenues.
Because such a small fragment of the industn is impacted by the rule, changes in the cost of
production for these facilities resulting from the rule will not influence market prices or
production
We determined the percentage of revenues that \\ill be consumed b\ compliance costs
and found that in nearh all cases, the impacts are ven minimal (ranging from 0.00% to 0.09%
for nearh all facilities). We found that only one faciliu had a moderate impact of 1.52 percent.
ho\\ever. with average industn profit margins of 3.6 percent, we conclude this impact will not be
significant to this faciliu. Overall. \\e conclude that this rule will have a minimal (and in most
cases negligible) impact on the industn. as well as the indhidual facilities and firms in the
mdu->tr\.
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ECONOMIC IMPACT ANALYSIS OF
THE LEATHER TANNING AND FINISHING
OPERATIONS NESHAP
1 INTRODUCTION
Under section 112(d) of the Clean Air Act as Amended in 1990. the U.S.
Em ironmental Protection Agenc> (referred to as EPA or the Agenc> ) is developing National
Emissions Standards for Hazardous Air Pollutants (NESHAP) for the leather tanning and
finishing industn . As part of the Agenc\ "s evaluation of impacts associated with the rule. \ve
ha\e prepared estimates of the total compliance costs and emission reductions that will result
from the rule. This report uses information about the affected leather tanners and the compliance
costs to e\aluate the economic impacts on the industn and on indhidual producers.
2 INDUSTRY PROFILE
Leather tanners produce materials for several consumer markets, including: automotive
seats: shoes, handbags, and gloves: sports equipment: furniture and home furnishings: and
clothes. According to Leather Facts published b\ the Ne\\ England Tanners Club, the hides and
skins used to create these goods come from all over the world and from a variety of animals'.
Most production in the U.S. comes from cattle, sheep, and pigs, but considerable quantities of
other types of hides and skins are also produced, including: horse, walrus, buffalo, deer. goat.
ostrich, crocodile, and other large and small animals. Table 2-1 shows some of the products
made with these different types of hides and skins.
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Table 2-1. Products of Leather Hides and Skins
TYPE OF HIDE END USE APPLICATION
and Steer Shoe and boot uppers, soles, insoles: patent leather: garments: work
gloves: belts; luggage: upholster,: transmission belts: sporting
goods
Calf Shoe uppers: slippers; handbags and billfolds: hat sweatbands:
bookbindings
Sheep and Lamb Grain and suede garments: shoe linings: slippers: dress and work
gloves: hat sweatbands: bookbindings: novelties
Goat and Kid Shoe uppers, linings: dress glo\es: garments: handbags
Pig Shoe suede uppers: dress and work glo\es: billfolds: fancy leather
goods
Deer Dress gloves: moccasins: garments
Horse Shoe uppers: straps: sporting goods
Reptile Shoe uppers: handbags: fancy leather goods
Source: Leather Fuels. New England Tanners Club: 1994.
2.1 Production Overview
Leather Fads provides a basic description of the typical process for comerting a cow
hide into a leather shoe upper. The leather tanning and finishing process can be divided into wet
operations and dry operations. A process flow diagram is provided in Figure 2-1. The wet
operations include all of the processes required for leather tanning. These processes include
steps to purify and stabilize the collagen content of the hide. Collagen is the protein responsible
for strength and toughness. Dry operations consist mostly of processes that enhance the natural
characteristics of the leather, which encompass the leather finishing processes2. For each tanner.
however, the techniques and chemicals used at each step is uniquely tailored to the product
qualities the> strive to achieve, and thus may differ slightly from this description.
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Figure 2-1. Leather Tanning and Finishing Processes - Flow Diagram
Wet Operations
Dry Operation!
Raw
Materials
Bating
• Retanning
Drying
Soaking
Pickling
Coloring
Conditioning
Unhairing
Tanning
Fatliquoring
Staking/
Milling
Trimming/
Siding
Buffing
Splitting
Finishing
Grading/
Measuring
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HcV Operations •
Before the tanning faciliu receives the hides, the raw material must undergo a curing
process at the supplier's faciliu (typically a meat packer) to prevent any deterioration and decay of
the product. The hides are then shipped to the tannery b\ truck or freight cars, which can deliver
about 1000 hides at a time (weighing about 50.000 pounds). The first step in the tanning process is
to prepare the hide for processing b\ sorting the hides by type, thickness, and other characteristics.
and storing them to prevent any deterioration of the hide. The next step is to soak a selection of
hides in a solution of water, chemical \\etting agents (similar to household detergents) and
disinfectants to restore the moisture that was lost during the curing process. The tanner then adds
chemicals to the soaking solution to complete the next step, the unhairing process, \\hich remoxes
the hair, epidermis, and certain soluble proteins.
Next, the hides go through a bating process to remove the residual unhairing chemicals and
non-leather making substances. In the first phase of the bating process, termed deliming. the hides
are placed in c> lindrical drums that have hollo\\ axles and are rotated \\ith water and chemicals to
remo\e am lime and alkaline chemicals present on the hides. In the second phase of this process.
the "bate" is added, which attacks and destroys most of the remaining undesirable constituents of
the hide (i.e.. hair roots, pigment, grain of the hide). Then the hides are washed to prepare them
for the pickling process of the operation. Hides are pickled by adding common salt (or other
chemicals that act in the same manner) and acid to the same drum as is used for bating the hide.
This step helps to preserve the hides until they are needed for the tanning process and also prepares
the hides to better accept the tanning materials.
The tanning process is the conversion of the raw collagen fibers of the hide in to a stable
product which is no longer susceptible to putrefaction or rotting. In addition to stabilizing the
product, this step significantly improves many of the properties of the hide (i.e.. abrasion resistance.
resistance to chemicals or heat, flexibility, ability to endure repeated cycles of wetting and dning).
This process is completed by adding chemicals to the same drums used for the bating and pickling
processes. The most common tanning agent is chromium sulfate. which imparts a blue-green color
to the hides. Other chemicals are also added to achieve other desired characteristics in the leather.
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Alter the tanning process is complete the hides are sent through a machine to wring the excess
moisture out of the hide. The\ are then sorted and trimmed to remove the perimeter areas of the
hide. Finalh . the\ are sent to splitting and shaving which adjusts the thickness of the leather
required for the desired end use.
Once the tanning process is complete and the hides are prepared to the desired thickness.
they undergo the steps of retanning. coloring, and fatliquoring. The retanning and coloring are
performed to achie\e specific end-use properties, and the fatliquoring pro\ides lubrication of the
fibers for flexibility and softness.
Dn Operations
After passing through the \\et end processes, the leather tanning and finishing process moves
to the finishing room. In the finishing room, the hides undergo the drying, conditioning, staking.
buffing, and finishing processes. The objecthe of the dr\ operations is to produce a product that
has uniformiu. resistance to scuffing and abrasion, appearance characteristics, and other desired
characteristics b> a commercial product such as upholster, or foot\\ear.
The leather is dried, conditioned, staked and mechanically dry-milled to further improve
flexibility and softness. Then the leather is goes through a buffing process to smooth the grain
surface b\ mechanical!} sanding.
The next step in the operation is to finish the leather. In this step, film-forming materials are
applied to the grain to provide abrasion and stain resistance and to enhance the color. This step
requires a lot of creativiu . skill, and expertise by the finisher who uses chemical coating substances
to achieve the desired end-product. To complete this step, almost a limitless combination of leather
coatings or finishes are applied, depending on the type of leather being produced and the intended
end use. T\pically. three to five coats of finish are applied to the leather although the actual number
of coats can van, depending on desired characteristics. The different types of finishes include stains
or d\es. pigments, binders, and top coats or sealer coats. Stains and dyes impart color belou the
surface of the leather. Pigments impart color to the top surface leather by forming a film on the
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surface of the leather. Pigments are also used to hide imperfections. Binders form a film on the
leather and create a smooth surface. They also bind stains and pigments to the leather and retard
bleeding and fading of the color. Top coats seal and protect the finished leather surface from
abrasion and prevent the color of the leather from bleeding. They also give a smooth, slick feel to
the leather and depending on the formulation will give the leather a particular luster.
Hundreds of leather finishing formulations are a\ailable: each finish formulation has unique
chemical and physical characteristics and is applied as needed to meet end-use requirements. The
finishes used are primarih broken down into four major leather industn sectors, including:
automothe upholsten leather, non-automotive upholsten leather, waterproof leather, and non-
waterproof leathers. Due to differences in the types of finishes required to achie\e specific
characteristics in leather, the EPA has established four subcategories of operations for the
de\elopment of the regulation. The four subcategories represent the major leather industry sectors
discussed above, and are described below:
L'phohlery Leather \vith Add-On Ic'.ss Than -/£,//'" This category produces leather for
automoii\e seating. Finishes for automotive upholsten are typicalh \\ater-based and ha\e
lower HAP emissions. They are based on acn lie resins and poh urethane dispersions. The
polyurethane component provides toughness, while the acrylic resin lowers the formulation
price. A small amount of organic solvents are used to act as a salting agent. Glycol ethers
are also used as diluents and coalescing agents, improving the film-forming properties of the
finish.
Upholsten' Leather with Add-On Greater Than or Equal to -Is if' This category produces
leather typically for use in furniture. The base coats for non-automotive upholstery finishes
are generally water-based. The top coasts can be either water-based or solvent-based
depending on the end-use of the leather. Low cost types of leather furniture upholstery are
intended to be functional at competitively prices and are typically finished with water-based
top coats. In contrast, "high-end" furniture upholstery leather is typicalh finished with
lacquer-based top coats to obtain the desired appearance and feel.
\Vater-Resi\tanl Leather: Water-resistant leather is used in a variety of applications, but
most common in shoe uppers. While the waterproof properties of leather can be achieved
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through \\et end processes, most facilities achieve the \vaterproofproperties of the leather
almost entirely through the finishing process. After wet end processes are complete, the
leather is spra\ d>ed with a solution composed mostly of HAPs. The dyeing is often
followed b> the application of a \\ax or oil. or a mixture of both. The wax and oil both
significant!) enhance the waterproof properties that are obtained through the wet processes.
\on Wtucr-Rcsislcmt Leather. This category is also used in a variety of applications, but the
most common market again is shoe leather. Finishes for non-waterproof leather are similar
to those used in non-automotive leather upholstery. Most base coats are water-based, and
the top coats are usualh \\ater-based but some are solvent-based.
The EPA has found that although the source categon includes facilities that perform both
leather tanning and finishing operations. \\e believe emissions from the leather tanning (wet
operations) are negligible compared to emissions from leather finishing (dry operations). Thus, the
rule is applicable onh to the leather finishing operations included in the subcategories stated abo\e.
The rule applies to the stains, pigments, binders, and sealers used in the finishing processes. The
NESHAP \\ill apph to all finishing application areas and equipment, including: spra\ booths.
brush applications, hand applications, roll coaters. manual swabbing, curtain coaters. and flo\\
coaters. It also applies to Hash-off areas, dning o\ens. infrared dryers, catalytic dners. open-air
drxing. cleaning, mixing, storage, and waste handling.
2.2 Producers of Finished Leather Products
Leather Facts states "there is scarce!) a country of any size which does not produce hides or
skins for comersion into leather."' Thus, there is a large international market for finished leather as
\\ell as trading the raw hides and skins. Some of the top world producers of cattle that can be used
for leather production include: Soviet Union. United States. Western Europe. Argentina. Eastern
Europe. Brazil, and Asia. For the U.S.. tanning activities are concentrated in the Northeast.
Midwest. Mid Atlantic States and California. Some tanneries are relatively small often specializing
in the manufacture of a particular kind of leather, and handing down the techniques from generation
to generation. Others employ several hundred people and produce a wide variet) of leathers'4.
According to the 1992 Census of Manufacturers, the top 20 companies in the industry accounted for
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74% of the products produced in the industn . and the top 8 companies accounted for over 50% of
the industry products5. This indicates that the smaller companies probably specialize in niche
markets and unique products, while the larger companies produce a large majority of the goods sold.
and can influence market price levels.
Because leather products are used in such a large variety of applications throughout the
world, the industry has a formidable market. As Table 2-2 shows, in 1993 leather tanning and
finishing was a S3.2 billion industn.- in the U.S.. emplcning 16.900 people in 330 establishments
and accounting for $700 million in exports6. In 1996. the industry \alue of shipments was $3.1
billion and emplo>ed 14.800 people and accounting for $951 million in exports'". During this time
period. emplo> merit dropped by 12% yet total shipments remained fairh steady around $3.0 billion.
The industn also mo\ed from being a slight net exporter in 1993 to becoming a slight net importer
of products from 1994 to 1996.
Table 2-2. Leather Tanning and Finishing Industry Statistics:
Emplovment and Value of Shipments (1993-1996)
Number of Employees
Value of Shipments (millions)
Imports
Exports
1993
16.900
$3.198
$736
$764
1994
15.900
$3.041
$960
$812
1995
15.300
$3.119
$1.089
$870
1996
14.800
$3.134
$1.139
$951
Sources Industn Outlook: U.S Department of Commerce. Bureau of Census: 1998
Annual Surve\ of Manufacturers: U S. Department of Commerce. Bureau of Census. 1996
According to data collected by EPA. there are 16 facilities that emit more than 10 tons/year
of a single HAP or 25 tons/year of a combination of HAPs. and are thus determined to be "major
sources" for the NESHAP. Table 2-3 displays the location and name of the facilities impacted by
this rule.
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Table 2-3. Facilities Affected by the Leather Tanning & Finishing NESHAP
Facility Name
Alliance Leather. Inc
Cudahx Tanning Companx
Elmo Leather of America
Gardenstate Tanning
Gardenstate Tanning
Gntman Leather Companx . Inc
Horueen Leather Companv
Irving Tanning Company
Lackawanna Leather Compain
Lackawanna Leather Company
Paul Flagg Leather Company
Prime Tanning Compain
S B Foot Tanning
Seton Company
Salz Leathers. Inc
Volunteer Leather Company
Location
Peabodx . MA
Cudahy. WI
Edison. NJ
Fleetwood, PA
Williamsport MD
Chicago. IL
Chicago. IL
Hartland. ME
Concner. KC
Omaha. NE
Sheboxgan. \VI
Rochester. NH
Red \\ ing. MN
NornstcuMi. PA
Santa Cruz. CA
Milan. TN
Industry Gron //?
As is mentioned at the beginning of this section, the leather tanning and finishing industry
supplies leather to a variety of industry sectors which include automotive upholster}. non-
automotive upholster}-, men's and women's shoes, athletic shoes, leather gloves and mittens.
luggage, women's handbags and purses, small personal goods, and leather clothing. To determine
how these markets can influence the leather tanning and finishing industry. Table 2-4 shows the five
year forecast of growth for the various leather industrv sectors.89
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Table 2-4. Five Year Growth Projections for Leather Industry Markets
Leather Industry Market
Automotive Upholster)
Non-Automothe Upholster)1 (furniture)
Men's Shoes
Women's Shoes
Athletic Shoes
Glo\es and Mittens
Luggage
Women's Handbags and Purses
Small Personal Goods
Leather Clothine
Five Year Growth Projection
(Annual Growth %)
4 to 5
4 to 5
2
little to no growth
1
-1.8
-2.7
-7.3
no change
-1.5
Source U S Industry, & Trade Outlook '98.. U S. Department of Commerce.
The oxerall forecast of growth for the leather tanning and finishing industn. is 2 to 3 percent
annual!) over the next five years. The fastest growing and potentially the largest markets for leather
in the U.S. are those for automotive upholstery and furniture upholstery. While shipments in the
markets for leather gloves and mittens, luggage, women's handbags, and leather clothing are
expected to decline in the next five years, shipments of leather to the automotive and non-
automothe upholster) sectors industn, sectors are projected to grow annual!) four to five percent.
Shipments for men's shoes is expected to grow by two percent annually, and the leather athletic
shoes market is expected to grow by one percent annually over the next five years. Thus, it appears
there will be a shift in current production of finished leather products from the markets with
declining growth to the markets with large expected growth.
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3 ECONOMIC IMPACTS
The NESHAP on the leather tanning and finishing industn requires affected facilities to use
different formulations of finishing products or requires them to modify finishing equipment to
reduce emissions to the MACT floor. A memorandum to the project files titled. "MACT floor
Emission Limits for Leather Tanning and Finishing Operations" provides details on the
development of the regulator) alternatives for this rule10. The costs to comply with the regulation
will \an across facilities depending upon the subcategory to which the\ are included, the current
finishing operations, and baseline emission control equipment. These regulator) costs will ha\e
financial implications for the affected producers, and possibly broader implications as these effects
are transmitted through market relationships to other producers and consumers.
3.1 Summary of Compliance Costs
In a memo to the project files titled. "Cost Impacts Associated \\ith HAP Emission
Reductions for Leather Tanning and Finishing Operations." (September 2. 1999). the EPA has
determined that total compliance costs imposed on the 16 affected facilities described earlier".
Overall, five facilities \\ill experience costs ranging from $0 to $883. while the remaining 11
facilities experience estimated costs of S8.515 to $105.590. The priman reason for a difference in
cost between these groups of facilities is that as a result of the regulation, some of the facilities will
be able to recapture some of the chemicals and product in the process to save on costs of
production. The total annualized cost of the rule is $437.589. which represents only 0.0014% of
total industn re\enues (based on 1996 \alue of shipments).
3.2 Market Impacts
Typically, our economic analyses take several data elements to input to a model that
determines changes in market prices, output, and total social cost (via the change in producer and
consumer surplus). Ho\\ever. the impacts of this rule are not likely to produce any measurable
changes in an economic model of the Leather Tanning and Finishing industn for the following
reasons:
11
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on!) 16 facilities out of the 330 establishments are affected.
total compliance cost represents a small percentage (0.0014%) of total market revenues.
the largest producers account for a large percentage of market share (i.e.. percentage of total
production).
\Ye can conclude in general that because a model of the market is not likely to show am
changes resulting from the costs imposed by this regulation, the market as a whole will not show
adjustments in price and production and affected producers will not be able to recover any of the
compliance costs incurred b\ raising prices. Likewise, while production levels at some of the
affected facilities ma) lower due to the increase in cost of production, other facilities will
compensate for this change such that overall industr) production vail not change.
Rather than perform a full market analysis, the analysis takes a closer look at the firm-level
impacts if \\e assume all costs will be absorbed by the owner of the leather tannery. We do this by
determining the percentage of revenues that the compliance cost \\ill consume. Using data
collected from Dun and Bradstreet. we found that the 16 affected facilities are owned b) 14 ultimate
parent firms'2. \Ve \\ere able to obtain revenue and employment data for 9 of the 14 firms. For the
affected facilities, the compliance costs as a percentage of firm revenues ranges from 0.00 to 1.52
percent. Tvpical profit margins in the industry average approximate!) 3.6 percent1'. Therefore, the
impacts presented b) this rule are like!) to be minimal on all of the firms owning the affected
tanneries.
3.3 Small Entity Screening Analysis
This regulator) action will potential!) affect the economic welfare of the owners of leather
tanneries. The ownership of these facilities ultimately falls on private individuals who may be
owner/operators that directly conduct the business of the firms, or more commonly, on investors or
stockholders that employ others to conduct the business of the firm on their behalf (i.e.. private!) or
public corporations). The individuals that manage these facilities have the capacity to conduct
business transactions and make business decisions that affect the facility . The legal and financial
responsibility for compliance \\ith the regulation ultimate!) rests with the facilit) managers:
12
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ho\\e\er. the o\\ners must bear the financial consequence of the decisions. Environmental
regulations like this rule potential!} affect all businesses, large and small, but small businesses may
ha\e special problems in complying with federal regulations.
The Regulator} Flexibility Act (RFA) of 1980 requires that special consideration be given to
small entities affected b} federal regulation. The RFA was amended in 1996 by the Small Business
Regulator} Enforcement Fairness Act (SBREFA) to strengthen the RFA's analytical and procedural
requirements. The RFA and SBREFA require the preparation of a regulatory flexibility analysis for
an} rule that \\ould have a significant impact on a substantial number of small entities, or a
disproportionate impact on small entities.
This section identifies the businesses that \\ill be affected b} this rule and provides a
preliminary screening-le\el analysis to assist in determining whether the rule is likely to impose a
significant or disproportionate burden on small entities and whether a regulatory flexibility anal} sis
is required under the RFA. The screening-le\ el anal} sis emplo} ed here is a "sales test." which
computes the annualized compliance costs as a share of sales for each company.
The Small Business Administration defines a small entity in the leather and tanning industry
as one \\ith total employment at the parent company of less than 500 employees. As is stated in the
pre\ious section, we collected data from Dun and Bradstreet and determined that the 16 affected
facilities are owned by 14 ultimate parent firms. We were able to obtain revenue and employment
data for 9 of the 14 firms and that 3 of these firms are classified as small. Many of the affected
facilities are small at the individual locations, but most are incorporated into larger firms.
The calculation of cost-to-sales ratios for the 9 firms shows that only one firm (owning one
facility and who is classified as small) shows an impact that is slightly greater than 1 percent of
revenues (1.52%). All other firms have impacts well below 1/1 Oth of one percent (impacts ranee
from 0.00% to 0.09% of firm revenues). As is stated earlier, profit margins in this industry are on
average aboxe 3 percent. Therefore, because the observed impacts are \\ell below typical profit
margins in the industry. we conclude that there will not be a significant impact on a substantial
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number of small entities, and that the impacts are not disproportionate between small and large
firms
4 SUMMARY
The U.S. is a key player in the world market for leather goods. We are a top producer in all
facets of leather production, including:
• raising cattle, sheep, pigs, and other animals:
• tanning and finishing hides and skins: and
• manufacture of finished leather goods.
The regulation developed by the EPA to reduce emissions of HAPs \\ill impact 16 facilities
in the leather tanning and finishing industry and are owned b\ 14 parent companies. The industn
includes approximate]} 300 establishments in all. therefore, the affected producers represent a ven
small fraction of the leather tanning production in the U.S. The regulation is expected to cost a total
of $437.589 annualh . which is 0.0014 percent of industry rexenues. Because such a small fragment
of the industn is impacted b\ the rule, changes in the cost of production for these facilities resulting
from the rule will not influence market prices or production.
We determined the percentage of revenues that will be consumed by compliance costs and
found that in nearh all cases, the impacts are very minimal (ranging from 0.00% to 0.09% for
nearly all facilities). We found that only one facility had a moderate impact of 1.52 percent.
ho\\e\er. with average industry profit margins of 3.6 percent, we conclude this impact will not be
significant to this facility. Overall, we conclude that this rule will have a minimal (and in most
cases negligible) impact on the industry", as well as the individual facilities and firms in the industry1.
14
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5 REFERENCES
Ne\\ England Tanners Club: "Leather Facts: A Picturesque Account of One of Nature's
Miracles." 1994.
Alpha Gamma Technologies. Inc.: "Industn Description for Leather Tanning and
Finishing Operations." Memo to Leather Tanning and Finishing Operations NESHAP
Project File: April 8. 1997.
3. Reference 1 .
4. Reference 1 .
5. U.S. Department of Commerce: Bureau of Census. Census of Manufacturers:
"Concentration Ratios in Manufacturing:" Publication # MC92-S-2.
6. Reference 1 .
7. U.S. Department of Commerce: Bureau of Census: 1996 Annual Sur\e> of
Manufacturers. Statistics for Industn Groups and Industries. 1996.
8. Reference 2.
9. U.S. Department of Commerce. International Trade Administration. U.S. Industn Trade
& Outlook'98.. McGra\\-Hill.Ne\\ York. Ne\\ York. 1998.
1 0. Alpha Gamma Technologies. Inc.: "MACT Floor Emission Limits for Leather Tanning
and Finishing Operations." Memo to Leather Tanning and Finishing Operations NESHAP
Project File: December 9 .1999.
1 1 . Alpha Gamma Technologies. Inc.: "Cost Impacts Associated with HAP Emission
Reductions for Leather Tanning and Finishing Operations." Memo to Leather Tanning
and Finishing Operations NESHAP Project File: September 2. 1999.
12. Dun and Bradstreet financial data obtained through confidential access of EPA IDEAs
database. Data contained in the Office of Air Quality Planning and Standards: Planning.
Resources & Regional Management Staff: Clean Air Act Confidential Business
Information Files.
13. U.S. Department of Commerce: Bureau of Census: Quarterly Financial Reports for
Manufacturing. Mining, and Trade Corporations: Quarter for 1998.; website address
<\\-\\A\ . census. go\ /prod'99pubs/qfr-98q4.pdf>.
15
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TECHNICAL REPORT DATA
(Plaice rend Instructions on re\er^c btfcii' (.ompleting)
} kLFORT NO :
EPA-452/R-00-002
4 TITLE AND SI BTITLE
Economic Impact Analysis of the Leather Tanning and Finishing
Operations NESHAP
7 AUTHORiS)
Lisa Conner: EPA. OAQPS
4 PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Aaency
Office of Air Qualitx Planning and Standards
Air Quality Planning and Strategies Division (MD-15)
Research Triangle Park. NC 27711
12 SPONSORING AGENO NAME AND ADDRESS
John Seitz. Director
Oftice of Air Quality Planning and Standards
Office of Air and Radiation
U.S Environmental Protection Agency
Research Triansle Park. NC 277*1 1
3 RECIPIENT'S ACCESSION NO
5 REPORT DATE
July 2000
6 PERFORMING ORGANIZATION CODE
8 PERFORMING ORGANIZATION REPORT NO
10 PROGRAM ELEMENT NO
11 CONTRACT GRANT NO
13 TYPE OF REPORT AND
14 SPONSORING AGENCY
EPA/200/04
PERIOD COVERED
CODE
1? SL PPLEMENTAR^i NOTES
In ABSTRACT
This report presents a technical analysis of the economic impacts associated with the proposed NESHAP
for Leather Tanning and Finishing Operations. The analysis evaluates adjustments in the leather market
(through price and production changes), social cost, and the resulting affects on employment, international
trade, and small businesses.
1" KE'l \\ORDS.AND DOCUMENT ANALYSIS
.. DESCRIPTORS
Economic Impact Analysis (El A)
Regulatory Flexibility Analysis (RFA)
IS DISTRIBUTION STATEMENT
Release Unlimited
h IDENTIFIERS OPEN ENDED TERMS
Air Pollution control
economic analysis
small business analysis
19 SECURITY CLASS (Reponi
Unclassified
20 SECURITY CLASS (Page)
Unclassified
c COSATI Field Gump
21 NO OF PAGES
22 PRICE
YP\ l-orm 2220-1
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