Prepublication issue for EPA libraries
         and State Solid Waste Management Agencies
                 ECONOMIC IMPACT ANALYSIS

   OF ANTICIPATED HAZARDOUS WASTE MANAGEMENT REGULATIONS

       OP THE LEATHER TANNING AND FINISHING INDUSTRY
      This report (SW-lS?c) describes work performed
for the Office of Solid Waste lender contract no.  68-01-4339
    and is reproduced as received from the contractor.
    The findings should be attributed to the contractor
           and not to the Office of Solid Waste.
     The reader is advised to utilize the information
        and data herein with caution and judgement.


             Copies will be available from the
          National Technical Information Service
                U.S. Department of Commerce
               Springfield, Virginia  22161
           U.S. ENVIRONMENTAL PROTECTION AGENCY

                           1978

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This report was prepared by Development Planning and Research
Associates, Inc., Manhattan, Kansas, under Contract No. 68-01-4339.

Publication does not signify that the contents necessarily reflect/
the views and policies of the U.S. Environmental Protection Agency,
nor does mention of commercial products constitute endorsement by
the U.S. Government.

An environmental protection publication (SW-157c) in the solid waste
management series.

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                               PREFACE
The attached document is a Contractor's study prepared with the supervision
and review of the Hazardous Waste Management Division of the U.S. Environ-
mental Protection Agency (EPA).  Its purpose is to provide a basis for
evaluating the potential economic impact of hazardous waste management
regulations established by EPA pursuant to the Resource Conservation and
Recovery Act of 1976 (P.L. 94-580).

The study supplements EPA technical studies on assessment of hazardous     ;
waste and costs of complying with the hazardous waste management regula-
tion for the leather tanning and finishing industry.   The technical studies
survey existing and potential waste streams and disposal methods and
technologies within this category and presents the costs associated with
appropriate control technology.  This study supplements those analyses by
estimating the broader economic effects (including product price increases,
continued viability of affected plants, employment, industry growth and
foreign trade) of the compliance by a specified disposal technology.

This study has been submitted in fulfillment of Contract No. 68-01-4339 by;
Development Planning and Research Associates, Inc.  Work was completed as
of February 1978.  The study is based primarily upon an earlier analysis
that had been completed by the Contractor which was modified and updated
to appropriately reflect recent changes that may have occurred.

This report represents the conclusions of the Contractor.  It has been re-
viewed by the Hazardous Waste Management Division of EPA and approved for
publication.  Approval does not signify that the contents necessarily re-
flect the views of the Environmental Protection Agency.

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                            TABLE OF CONTENTS

                                                                  Page

      EXECUTIVE  SUMMARY                                              vi

  I.   INTRODUCTION                                                   1
      A.   Scope  and  Organization  of this Report                     1
      B.   Data Sources                                               1

 II.   METHODOLOGY                                                   3
      A.   Industry Structure and  Subcategorization           ,       4
      B.   Financial  Profile of the Industry                         4
      C.   Model  Plants                                               6
      D.   Pricing Patterns                                           7
      E.   Waste  Treatment Technological  Options and Costs           7
      F.   Analysis of Economic Impacts                              7

III.   STRUCTURE  OF THE  INDUSTRY                                    17
      A.   Industry as a  Process                                    18
      B.   Characteristics of the  Industry                          18
      C.   Importance of  Integrated Capacities                      28
      D.   Level  rf Diversification                                 28
      E.   Employment Characteristics                               29
      F.   Ownership  Type and Size                                  31
      G.   Industry Segments                                        31

 IV.   FINANCIAL  CHARACTERIZATION  OF THE  INDUSTRY                   36
      A.   General Financial Situation                              36
      B.   Cost Structure of the Industry                           38
      C.   Industry Profitability                                    44
      D.   Financial  Structure of  the Industry                      47
      E.   Cost of Capital - After Tax                              50
      F.   Assessment of  Ability to Finance New Investment          51

 V.    PRICES  AND PRICE DETERMINATION                               54
      A.   Leather Prices, Demand, and Supply                       54
      B.   Imports of Finished Leather Products into the
           United States                                           61
      C.   The Raw Hide Market                                      68

 VI.   MODEL PLANTS                                                  78
      A.   Types  and  Sizes of Model Plants                          78
      B.   Investment                                               82
      C.   Model  Plant Capacity and Utilization                     84
      D.   Annual Sales of Model Plants                             84
      E.   Cost Structure of Model Plants                           85
      F.   Model  Plant Annual Profits                               92
      G.   Annual Cash Flows                                        92

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                   TABLE OF CONTENTS (continued)
 VII. HAZARD WASTE MANAGEMENT COSTS                                95
      A.  Hazardous Waste Management Guideline and
           Recommendations                                         95
      B.  Hazardous Waste Management Treatment and Disposal
           Technology                                              95
      C.  Status of Industry Hazardous Waste Management            96
      D.  Hazardous Waste Management Costs                         97

VIII. ECONOMIC IMPACT ANALYSIS            .                         99
      A.  Price Effects                                            99
      B.  Financial Effects                                       102
      C.  Production Effects                                      108
      D.  Employment and Community Effects                        110
      E.  Balance of Trade Effects                                110
 IX.  LIMITS OF THE ANALYSIS                                      111
      A.  General Accuracy                                        111
      B.  Range of Error                                          112
      C.  Critical Assumptions                                    113

 Selected References

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                           EXECUTIVE SUMMARY
The general purpose of this report is to present the economic impact
analysis of hazardous waste management regulations (Resource Conserva-
tive and Recovery Act of 1976, P.L.94-580) on the Leather Tanning and
Finishing Industry (SIC 3111).  Much of the emphasis for analysis was
placed on four major topics.   They included development of a methodology,
analysis of financial conditions,  analysis of pricing practices, and
projection of actual economic impacts.  In addition, the authors included
substantial information on the industry structure.  To follow is a summary
of the findings.

Methodology

The methodology of evaluating economic impacts included a comparison
between projections of effects on  certain economic variables or character-
istics with compliance with the given regulations and without compliance
(baseline).  Economic variables assessed include:  (1) price effects on
producers, consumers and suppliers,  (2) profitability and financial
status of the industry and plants, (3) expected plant closures, (4)
employment changes (5) community conditions, and (6) balance of payments.

Structure of the Industry

The Leather Tanning and Finishing  Industry, as defined within SIC 3111,
includes leather tanneries, converters and contract tanneries.   While
all are engaged in tanning, curing,  finishing, storing and marketing
leather, only the regular tanners  and some-contract tanners (leather
finishers) will be impacted by the regulations to control  hazardous
waste (HW).  Leather converters primarily buy hides and skins and
have them processed into leather on  a contract basis by others.  Their
establishments, therefore, do not  generate hazardous waste.

In 1976, there were estimated to be about 250 establishments that are
either regular leather tanneries or leather finishers who generate sub-
stantial amounts of solid waste.  Of these about 30 are vegetable tan-
neries and generally do not generate hazardous waste, thus leaving 220
potentially impacted plants.   Most, of the plants are located in the
Northeast and Lake States.

The size of plants varies  from a production of less than 100 hides per
day to over 2,000 hides per day.

The genera"! process of the industry includes converting a putrescible
raw animal hide  into usable finished  leather.  However, within this
general process  there is  virtually no end to the variety of leathers
than  can be produced.

Financial  Conditions

In recent years,  financial conditions exhibited  in the leather industry
have  been  depressed.  Three conditions account for much of the financial
                                   VI

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decline.  First, foreign leather and leather goods producers have gained
a large share of the U.S. leather market by underpricing U.S.  producers.
Second, foreign tanners also purchase large quantities of raw hides,
pushing their price up and increasing domestic tanners costs which are
difficult to pass on to consumers.   Finally, the availability of synthetic
substitutes has reduced aggregate demand for leather.

The situation has improved in 1974, 1975 and 1976, however, the financial
status of the leather industry does not appear to be highly favorable.

Profits before tax as a percent of sales average about 2 to 2^ percent in
the early 1970's and climbed to 6 and 6% percent in 1974 and 1975.  A 4 to
6 percent profit before tax can probably be expected for the immediate future.

Prices

The price of leather was at a record level in 1976 with a wholesale price of
$1.11 per square foot.  This is up from a price of $.80 per square foot the
previous year.  Price fluctuations in the 1970's represent the first major
price movements in the industry  in about 10 years as prices during the 1960's
were relatively stable at around $.60 to $.65 per square foot.

Hide prices have moved in a fashion similar to wholesale leather prices as
there is typically a somewhat stable hide to leather price spread.

Economic Impacts

Based on costs provided by the EPA technical contractor- , economic impacts
were analyzed on key industry factors including:  (1) price, (2) financial
conditions, (3) production, (4) employment, (5) communities and (6) foreign
trade.  For the most part, the impacts on the industry are expected to be modest.

The price increase required to offset HW disposal  costs and maintain profits
for the industry will generally be 0.5 percent or less of the product prices
for the various segments of the industry.  However, two industry segments
would require substantially higher percentage price increases.   Thru-the-
blue cattlehide and cattle split tanners would require price increases of
1.8 and 3.4 percent respectively.  This reflects a combination of less valu-
able final  products and relatively high waste generation per unit of production.

Because they operate in a highly competitive market, tanners have little
success in passing through increased costs of production to consumers.
Thus, the expscted price increases actually occurring are estimated to be
only a small portion of the required price increases listed above.

Generally, the impacts on financial conditions in the industry will be small.
However, thru-to-blue and split tanners will be exceptions, as impacted
]_/ Battelle Columbus Laboratories, Cost of Complying with Hazardous Waste
   Management Regulations, draft report for EPA, Contract No. 68-01-4360,
   October 12, 1977.
                                  Vll

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plants in these segments are estimated to have after-tax incomes reduced
39 percent and 57 percent respectively.   Considering only HW management
requirements, both types of plants would maintain positive income streams
and positive net present values.   However, if HW management costs are 20
or more percent higher than those provided for the study, then split tanners
are estimated to become financially threatened as their net present values
become negative.

As plants are expected to be able to maintain profitability after costs for
hazardous waste management, no plant closures are estimated to occur solely
because of HW management regulations.  Therefore, production losses attribu-
table to the regulation are estimated to be minimal, if any.

The small impacts on prices, plant profitability and production establish
the level of impacts on the other critical economic variables considered;
employment, community and balance of trade effects.  For each of these areas
of concern, impacts from hazardous waste management regulations are expected
to be small.
                                  VI11

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                      I.  INTRODUCTION
          A.  Scope and Organization of this Report

The Environmental Protection Agency is responsible for establishing
hazardous waste management regulations for various industries including
the Leather Tanning and Finishing Industry (Standard Industrial Classi-
fication 3111) under the provisions of the Resource Conservation and
Recovery Act of 1976.  The purpose of this report is to analyze the
economic impact of such regulations on the Leather Tanning and Finishing
Industry.

There are four phases of analysis included in the work scope.  They include:
(1) determination of the financial structure of the impacted industrial
sectors, (2) assessment of the pricing practices and effects in the industry,
(3) development of an impact analysis methodology, and (4) estimation and
projection of actual economic impact.

The following economic impacts were analyzed and, to the extend that they
were found to be significant, are described in this report.

     1.  Price and production effects - short and long-run effects on
         suppliers and consumers, possible curtailments and closures
         with special attention to small businesses;

     2.  Financial effects - pre-tax income, other profit parameters
         and capital availability;

     3.  Employment and wage effects;

     4.  Community impacts; and

     5.  Foreign trade consequences.


 The basic organization of this report consists of establishing the overall
 Tanning Industry's situation including discussions on the industry's struc-
 ture,  financial  and pricing characteristics.   From these data, representative
 model  plants are developed which serve as a baseline (before hazardous waste
 management regulations)  from which impacts can be measured.   Finally, the
 model  plants are impacted utilizing waste management costs provided by EPA
 and the overall  industry impacts determined.

                                B.  Data Sources

 The most commonly used and, in many cases, the most readily available sources
 of industry information  including employment,  location,  value of shipment
 and product data are available from the U.S.  Department  of Commerce, parti-
 cularly its Census of Manufactures. Annual Survey of Manufactures and In-
 dustrial Outlook.   Additionally, the Tanners'  Council of America publ ishes
 an annual  report,  the Leather Industry Statistics, which contains the most
 recent industry production data.  Financial  data are somewhat limited as
 much of the published data are aggregated such that information concerning

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just the Leather Tanning Industry are not available.   These sources of
financial data include the Robert Morris Associates,  Statement Studies;
Troy's Almanac of Business and Industrial Financial  Ratios; and the
Internal Revenue Service's, Source Book of Statistics of Income.

The above sources do provide sufficient data such that generalizations
concerning the industry as a whole can be made.   However, much more de-
tailed information was required in order to accurately represent the in-
dustry for the impact analysis.  Information of such  a nature was obtained
from a recently distributed data collection portfolio which provided vdata
on about 200 tanneries in the industry.]./

Of the 302 data collection portfolios sent, 135 responses were received
reflecting various stages of completion.  A technical contractor also
utilized a survey of the industry and was able to provide additional
information concerning some 65 tanneries.  Thus, in  total, some infor-
mation was available for about 200 tanneries in the  industry.

Also, plant visitations were utilized to gain insight to problems about
the industry, its operation, and foreseeable problems concerning the
implementation of waste management regulations.
If  The data collection portfolios were developed,  distributed and analyzed
    under EPA Contract No.  68-01-4182 dated 9/20/76 as amended.   The study
    was designed to assess  the economic impact of water effluent controls
    on the leather tanning  industry.

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                          II.   METHODOLOGY
The methodological approach utilized to assess  the likely economic impact
of proposed hazardous waste management requirements pursuant, to the
Resource Conservation and Recovery Act of 1976  (P.L.  94-580)  on the
Leather Tanning and Finishing Industries is summarized in this  chapter.

In this study, economic impact is defined as the comparison between (1)
the projections of the likely effects on plant, local  area, U.S. and
foreign activity which would result from an industry's compliance with
a given level of hazardous waste management requirements and (2) projec-
tion of industrial activity and changes which would likely occur in the
absence of the Act (baseline).

In particular, the principal economic variables of interest in  this
study are:

       1.  Price effects - including effects upon industry's suppliers
           and consumers

       2.  Profitability, growth and capital availability

       3.  Number, size, and location of plants that can be expected to
           close or curtail productions

       4.  Changes in employment

       5.  Community impacts

       6.  Balance of payments consequences

       7.  Any other impacts

Economic impacts were evaluated for hazardous waste management which is
defined practices involved in the handling and disposal of such land
destined waste.  Waste management requirements for the Leather Tanning
and Finishing  Industry are described in a separate EPA report I/.

The impact analyses focus on price increases, plant closures, curtail-
ment of production, dislocations of production, unemployment, community
Impacts, and  balance of trade effects.
 I/  Battelle Columbus Laboratories, Cost of Complying with Hazardous Waste
    Management Regulations, draft report for EPA, Contract No. 68-01-4360,
    October 12, 1977.

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Several interrelated analyses are used to evaluate likely economic impacts
resulting from hazardous waste management regulations on the Leather Tanning
and Finishing.Industry.  These in-depth analyses include:  (1) characteriza-
tion and subcategorization of the technical and economic structure of the
industry and segments, (2) description of the financial profile of the
industry and segments, (3) construction of representative model plants,
(4) evaluation of pricing patterns within the industry, (5) determination
of technological options for meeting designated levels of solid waste
management and the costs associated with each option, and (6) analysis of
economic impacts.

The analysis, however, is not a simple sequential analysis; rather it
employs interacting feedback steps.  The schematic of the analytical
approach is shown in Figure 1.   Due to the fundamental  causal relation-
ships among the financial and production effects and other impacts, a
greater emphasis is devoted to plant closure analysis.


            A.  Industry Structure and Subcategorization


The industry structure and subcategorization phase of the methodology
primarily involves describing and segmenting the industry in terms of past
and current economic characteristics.  The purpose of this phase of the
analysis is to provide an information base to be used in subsequent analysis.
In particular, the information on industry characteristics is useful in
determining an appropriate disaggregation design for industry subcategoriza-
ti on.

Subcategorization involves segmenting the plants within the industry into
relatively homogenous classes with respect to plant size, regional dif-
ferences, technology employed, number of products, existing level of
pollution, scale of technological processes, level of output, or other
relevant factors important for assessing the economic and financial
impact of waste management.  The delineation of industry subcategories
developed in the early stages of the analysis serves as the basis for
the definition and construction of representative model plants and the
determination of technological options and costs for waste handling and
disposal.

                B.  Financial Profile of the Industry


The ability of firms within the industry to pass on and/or absorb costs
for hazardous waste management is determined in part by past and expected
financial conditions of those firms.  Under the heading "financial pro-
file of the industry," various factors are studied to develop insight
into the financial characteristics of actual plants in the industry.  Much
of the data compiled in this section is also useful in determining finan-
cial profiles of representative model plants.

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                                    Industry
           Industry
           Structure
           Industry
           Financial
             Data
         EPA Hazardous
        Waste Management
            Costs
               Plant Closures
                   Due to
                 Regulation
          Employment
           Effects
             1
          Community
           Effects
  Subcate-
gorization
                                       1
                                  Model  Plant.
                                    Parameters
Budget Data
Development
                                     Model
                                   Financial
                                   Analyses
   Price
 Increases
 Shutdown
 Analysis
Production-
 Expected
  Effects
  Foreign
   Trade
  Effects
Industry
Pricing
                           Financial
                           Profiles
Figure 1.   Schematic of economic impact analysis of hazardous  solid waste
           management regulations.

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Key financial  statistics include after-tax profit as a percent of sales,
after-tax profit as a percent of invested capital, sales to total  assets
ratios, sales  per employee,  assets per employee,  and after-tax profit to
net worth.  As costs are generated primarily from paying for a service,
most impacts will be on current revenues and operating expenses.   Financial
factors related to the ability to finance new investments will not be
important as little, if any, investment will be required.  The data com-
piled in this  phase of the analysis provide an information base useful
for projecting key technical and economic factors and for carrying out
subsequent economic impact analysis.


                           C.  Model  Plants
The model plant concept represents a systematic framework from which to
assess likely economic impacts on individual  types and sizes  of actual
plants within the industry.   Usually more than one model  plant is  required
for an industry in order to  represent various types and sizes of existing
plants or plants which are likely to be constructed after the promulgation
of the regulations.

Model plants represent a variety of financial, economic,  and  technical
variables such ?s sales, investment, fixed and variable costs, profits,
size, type or process, etc.   Model plant profiles are constructed  from
data and information gathered in the industry characteristics and  sub-  .
categorization and financial  profile phases of a previous analysis.
Additional data, as required, are generally obtained from industry
representatives, trade publications, and from engineering cost-synthesis
methods.

The applicability of utilizing model plant data for assessing expected
economic impacts of hazardous waste management regulations rests prin-
cipally on the representativeness of the selected model plant(s).   For
example, the economic concept of "economies-of-scale" in production is
often present in processing  plants, e.g., average unit costs  of production
are usually lower in large plants as compared with medium or  small plants
of the same type.  Although  predicted to be small, the economies-of-scale
in solid waste management, in effect, will further compound the economies-
of-scale relationships among differing sizes of plants.

Other processing factors, e.g., type of manufacturing process employed
(technology) may also affect waste streams and, thus, impacts.  This
again may necessitate further segmentation of an industry and the  in-
clusion of additional model  plants for more comprehensive analysis.

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                        D.  Pricing Patterns


The analysis of pricing patterns in the Leather Tanning Industry focuses
on factors determining supply and demand.  Market structure and the nature
of competition are evaluated which, for the Leather Industry,  involves  the
inclusion of the influence that international  markets and competition
assert on the domestic industry's prices.  Finally, the ability of impacted
tanneries to recover the increased costs of hazardous waste regulations is
assessed.


        E.  Waste Treatment Technological Options and Costs


Hazardous waste management options and associated costs are made avail-
able from a separate EPA report I/.  The technical and cost data from the
report are general  and apply to certain categories of waste streams
developed in industries.  The acceptability and unit costs of  technology
used for waste stream categories are assumed to be constant for any size
or type of plant that produces a certain type of waste stream.   The tech-
nical study on costs of complying assumed all  leather tanners  create the
same waste stream .category, solids and sludges containing hazardous waste.
All leather tanners will be assumed to dispose of the waste in secured
landfills.

In relation to the model plants, the costs per metric ton of waste will
be constant for all plant sizes and segments.   Segments will produce
greater waste loads per unit of output and, thus, effect costs of waste
management.  Sizes of plants, however, will only be significant in
assessing the ability to cover costs as technical reports contain no
information relating size of plants to waste loads generated or costs.


                  F.  Analysis of Economic Impacts


In carrying out an economic impact analysis, it is important to establish
a baseline of industry conditions that are expected without regulations
and to estimate the impact in terms of the change from this baseline
attributable to the imposition of waste management regulations.  Thus,
in this study, a "dynamic baseline", namely a  projection of the industry
structure in terms of number of plants, production, employment and other
parameters over time, is used as opposed to a  "static" baseline which
assumes a baseline condition equivalent to that currently present.
I/  BatteHe Columbus  Laboratories,  Cost of Complying with Hazardous  Waste
    Management Regulations,  draft report for EPA,  Contract No.  68-01-4360,
    October 12, 1977.

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Fundamentally, the impact analysis is similar to that usually required
for any capital budgeting study of new investments.   The problem is one
of deciding whether a commitment of time or money to a project is worth-
while in terms of the expected benefits.  The analysis is complicated by
the fact that benefits and costs will accrue over a  period of time and
that, in practice, the analyst can not reflect all of the required
imponderables, which by definition must deal with future projections.
In the face of imperfect and incomplete information  and of time con-
straints, the industry segments are described in the form of financial
budgets of model plants.  Key non-quantifiable factors were considered
in the interpretation of the quantified data.  Actual financial results
will deviate form the model  results, and these variances will be considered
in interpreting the findings based on model plants.

The analysis of anticipated economic impacts of hazardous waste management
regulations are described as follows.

Fundamental Core Methodology

The fundamentals for analysis are basic to all impact studies.  The core
methodology is described here as a unit with the specific impact analyses
discussed under the appropriate headings following this section.

The core analysis for this study was based upon synthesizing the physical
and financial characteristics of the various industry segments through
representative model plant projections.  Estimated financial profiles
and cash flows are presented in the industry reports.  The primary factors
involved in assessing the financial and production impact of regulations
are profitability changes, which are a function of the cost of waste
management and the ability to pass along these costs in the form of
higher prices.  In reality, closure decisions are seldom made on a set
of well-defined and documented economic rules.  They include a wide range
of personal values, external forces such as the inability to obtain financing
or the relationship between a dependent production unit and its larger cost
center whose total costs must be considered.

Such circumstances include but are not limited to the following factors:

     1.  Inadequate accounting systems or procedures.  This is especially
         likely to occur in small, independent plants which do not have
         effective cost accounting systems.

     2.  Insufficient production units.  This is especially true of
         plants where the equipment is old and fully depreciated and
         the owner has no intention of replacing or modernizing them.
         Production continues as long as labor and materials costs are
         covered and/or until the equipment fails entirely.

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     3.   Personal  values and  goals  associated with business  ownership
         that override or constrain rational  economic rules.   This  com-
         plex of factors may  be referred to as the value of  psychic
         income.

     4.   Production dependence.  This  is characteristic  of a  plant  that
         is a part of a larger integrated entity which either uses  raw
         materials being produced profitably in another  of the firm's
         operating units or supplies raw materials to another of the
         firm's operations where the source of supply is critical.  When
         the profitability of the second operation more  than offsets the
         losses in the first  plant, the unprofitable operation may  con-
         tinue indefinitely because the total enterprise is  profitable.

     5.   Temporary unprofitability.  This may be found whenever an  owner-
         operator expects that losses  are temporary and  that adverse
         conditions will change.  His  ability to absorb  short-term
         losses depends upon  his access to funds through credit or
         personal  resources not presently utilized.

     6.   Low (approaching zero) opportunity costs for the fixed assets
         and for the owner-operator's  managerial skills  and/or labor.
         As long as the operator can meet labor and materials costs, he
         will continue to operate.   He may even operate  with gross
         revenues below variable costs until  he has exhausted his working
         capital  and credit.

     7.   Plant site appreciation.  This factor is important  in those
         situations where the value of the land on which the plant  is
         located is appreciating at. a  rate sufficient to offset short-
         term losses.

These factors are generally  associated with proprietorships and closely
held enterprises rather than  publicly held corporations.

While the above factors are present in and relevant to business decisions,
it is argued that common economic rules are sufficient to provide useful
and reliable insight into potential business responses to required  invest-
ment and operating costs in waste management handling.

In the simplest case, a plant will  be closed when variable costs (Vc)
are greater than revenues (R) since by closing the plant, losses can be
avoided.

In a more probable situation, the variable costs are less than revenues
but revenues are less than variable costs plus cash overhead expenses  (TCc)
which are fixed in the short-run.  In this situation, a  plant would likely
continue to operate as contributions are being made toward covering a

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portion of these fixed cash overhead expenses.   The  firm  cannot  operate
indefinitely under this condition,  but the length  of this period is  un-
certain.  Basic to this strategy of continuing  operations is  the firm's
expectations that revenues will  increase to cover  cash  outlay.   Identifica-
tion of plants where variable costs plus cash overhead  expenses  are
greater than revenues, but variable costs are less than revenues leads
to an estimate of plants that should be closed  over  some  period  of time
if revenues do not increase.   However, the timing  of such closures is
difficult to predict.

In another situation, the variable  costs plus cash overhead expenses are
less than revenues.   In this  case,  it is likely that plant operations
will continue if the net present value (NPV^) of the cash flow I/ at the
firm's (industry) cost of capital  (k) is greater than zero.   Ifthe  net
present value is less than zero, the firm could liquidate, realizing
salvage value (S) 2/ in cash, and reinvest and  be  financially better off,
assuming reinvesting at least at the firm's (industry)  cost of capital.

Computation of net present value involves discounting the cash flow
through the discounting function:

                              y               n
                     NPV  =   2     A  (1 + k)"n
                             n=0    n

where:

     NPV  =  net present value

      An  =  the cash flow in the n   year
       k  =  discount rate (after-tax cost of capital)
       n  =  number of conversion periods, i.e., 1 year,  2 years, etc.

       y  =  years

The "cash flow" including waste  management related costs  is described  in
the subsequent sections.

Construction of the Cash Flow

The cash flow used in the analysis  of hazardous waste management costs
was constructed as follows:
I/  Refer to "Construction of the Cash Flow".

2J  Salvage value is defined here as the liquidation value of fixed assets
    plus working capital.

                                 10

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     1.   Initial  investment taken in year t0, considered to be outlays
         for fixed assets and working capital.

     2.   After-tax cash proceeds taken for years t-|  to tn.

     3.   Annual replacement investment, equal to annual current depre-
         ciation  taken for years t]  to tn.

     4.   Terminal  value taken in year tn.

     5.   Annual hazardous waste management operating expenses are taken
         for years t-|  to tn.  No added investment is assumed to be
         required for  hazardous waste management.

Baseline cash flow excludes costs associated with managing  hazardous
solid waste.

It should be noted that a more common measure of profitability is return
on investment (ROI) where after-tax income (as defined in equation below)
is expressed as a percent of invested capital (book value)  or as a percent
of net worth.  These measures should not be viewed so much  as different
estimates of profitability compared to net present value, but rather these
should be seen as an entirely different profitability concept.

The data requirements  for return on investment and net present value
measures are derived from the same basic financial information, although
the final inputs  are handled differently for each.

In the construction of the cash flow for the net present value analysis,
after-tax cash proceeds are defined as:

     (1)  After-tax income = (1 - t) x (R - E - I - D)

     (2)  After-tax cash proceeds = (1 - t) x (R - E - D) + D

where

       t  =  tax  rate

       R  =  revenues
       c.  =  expenses  other than depreciation and interest
       I  =  interest  expenses
       D  =  depreciation charges

Depreciation is included only in terms of its tax effect and is then
added back to obtain after-tax cash proceeds.
                                 11

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There is a temptation to include outlays for interest payments  when com-
puting the cash proceeds of a period.  Cash disbursed for interest should
not affect the cash proceeds computation.   The interest factor  is  taken
into consideration by the use of the present-value procedure.   To  also
include the cash disbursement would result in double counting.   The
effect of interest payments on income taxes is also excluded  from  the
cash proceeds computation.  This is brought into the analysis when com-
puting the effective rate of interest of debt sources of capital,  which
is used in the determination of the cost of capital.

A tax rate of 20 percent on the first $25,000 income, 22 percent on
income from $25,001 to $50,000, and 48 percent on amounts over  $50,000
was used throughout the analysis.  Accelerated depreciation methods,
investment credits, carry forward and carry back provisions were not
used due to their complexity and special limitations.

Cost of Capital - After-tax

Return on invested capital is a fundamental notion in the U.S.  business.
It provides both a measure of the actual performance of a firm  as  well
as its expected performance.  In the latter case, it is also  called the
cost of capital and this, in turn, is defined as the weighted average of
the cost of each type of capital employed by the firm -- in general terms,
equities and interest-bearing liabilities.  There is no methodology that
yields the precise cost of capital, but it can be approximated  within
reasonable bounds.

The cost of equity capital is estimated by two methods -- the dividend
yield method and the earnings stock price (E/P ratio) method.   Both are
simplifications of the more complex DCF methodology.  The dividend
method is:
       c  =
where

       c  =  cost of equity capital

       D  =  dividend yield
       P  =  stock price

       g  =  growth

The E/P method is simply

       c  =  E/P
                                  12

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where

       c  =  cost of equity capital

       E  =  earnings

       P  =  stock price

and is a further simplification of the first.   The latter assumes  future
earnings as a level, perpetual stream.

The-after-tax cost of debt capital was estimated by using an estimated
cost of debt (interest rate) and multiplying it by 0.52 -- assuming a 48
percent tax rate.


       d  =  0.52 i


where

       d  =  after-tax cost of debt capital

       i  =  before-tax cost of debt (interest rate)

The sum of the cost of equity and debt capital weighted by the respective
equity to total assets and total liabilities to total  assets ratios
yields the estimated weighted average cost of capital  - after tax  (k).

Investment

In evaluating the feasibility of new plants, investment is thought of as
outlays for fixed assets and working capital.   However, in evaluating
closure of an on-going plant, the investment basis is  its salvage  value
(opportunity cost or shadow price) I/.   For this analysis, salvage
value was taken as the sum of liquidation value of fixed assets plus
working capital (current assets less current liabilities) tied up  by the
plant.  This same amount was taken as a negative investment or "cash
out" value in the terminal year.

The rationale for using total shadow priced investment was that the cash
proceeds do not include interest expenses which are reflected in the
weighted cost of capital.   This procedure requires the use of total
capital (salvage value) regardless of source.   An alternative would be
to use as investment, net cash realization (total less debt retirement)
upon liquidation of the plant.  In the single plant firm, debt retirement
would be clearly defined.   In the case of the multiplant firm, the delinea-
tion of the debt by the plant would likely not be clear.  Presumably this
\l  This should not be confused with a simple buy-sell  situation which
    merely involves a transfer of ownership from one firm to another.
    In this instance, the opportunity cost (shadow price) of the invest-
    ment may take on a different value.

                                  13

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could be reflected in proportioning total  debt to the individual  plant
on some plant parameter (i.e., capacity or sales).   Under  this  latter
procedure, interest and debt retirement costs would be included in the
cash flows.

The two procedures will yield similar results if the cost  of capital  and
the interest charges are estimated on a similar basis.   The former pro-
cedure, total salvage value, was used as it gives reasonable answers
and simplified both the computation and explanation of the cash proceeds
and salvage  values.

Replacement  investment was considered to be equal to the annual deprecia-
tion.  This  corresponds to the operating policies of some  managements
and serves as a good proxy for replacement in an on-going  business.

Again, no investment in hazardous waste management facilities is required
as disposal  will include payment for a disposal service.  This  cost will
affect return on the normal investment activities but will not  create
need for additional investment analysis.

Price and Production Impact Analyses

Price and production impact analyses necessarily have to proceed sim-
ultaneously.  In order to evaluate these impacts, two types of  analyses
are used:  one is at the micro level utilizing the model plant  as the
basis of the analysis to arrive at required price impacts  to maintain
profitability levels; the other is at the industry level utilizing supply
and demand analysis.

Application  of the preceding DCF procedure to these costs  yields the
present value of hazardous waste management costs (i.e., operating
cost less tax savings).  If this is known, the price increase required
to pay for hazardous waste management can readily be approximated by
the formula  I/
       x  =


where
(PVP)  (100)
U-T)  (PVR)
       X  =  required percentage increase in price

     PVP  =  present value of pollution control costs
I/  The above procedure is conceptually correct where an average tax
    rate is used.   However, to insure accuracy in the machine program
    where the actual tax brackets are incorporated, a more detailed
    iterative process is required.

                                  14

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     PVR  =  present value of gross revenue starting in the  year
             pollution control is imposed

       T  =  average tax rate

The required price increase at the plant level  is  evaluated  in  light  of
the price elasticities of the commodity involved and the competitive
structure of the industry.  This represents the second approach using
supply and demand analysis.  The supply and demand analysis  provides
some insights into likely quantities and supply response to  different
prices.  This allows a preliminary estimate of the production and  price
impact of regulation costs.  Following this, further analysis at the
micro level is performed to obtain a more detailed insight into the
plants' response to expected prices, absorption or shutdown. The  indicated
plant shutdowns are then aggregated to test whether or not the  lost pro-
duction could be absorbed by the remaining capacity or whether  such cur-
tailments would increase prices.

Financial Impact Analysis

The financial impact analysis involves preparation of pro forma income
statements and cash flow statements following the  assessment of the
likely price change.  The analysis provides estimates of profitability
with and without hazardous waste management costs.

Plant Closures and Production Effects

Plant closures may result from the inability of less profitable plants
to adequately recover required waste disposal cost through increased
product prices, decreased input prices, or improvements in economic
efficiency.  Often closures can be anticipated among older,  smaller,
and less efficient plants as a result of economies of scale which  would
lower the overall relative costs to a larger operation.  Consequently,
in the long run, it is expected that the older, smaller, less efficient
plants will eventually yield to the dominance of the larger more efficient
units.  However, in the short run, it is always possible that a plant may
continue to operate even when economic considerations indicate  closure.
Possible exceptions will occur to the extent that  smaller high  cost
plants are protected by regional markets and other non-price impediments
to competition from the larger low cost plants.

Employment Impact Analysis

This analysis is concerned with estimating likely  employment losses due
to curtailed production and/or plant closures as a result of the regula-
tions of concern.  If the actual plants which are  expected to curtail
production and/or close can be identified, employment impacts can  be
estimated directly.  Otherwise the employment impact analysis involves
the application of estimates of employment changes by model  plants.
Employment changes in model plants are then generalized according  to  the
number of actual plants represented by the model plant and aggregated to
derive an estimate of total employment effects for the industry.   Employ-
ment dislocations will be noted as appropriate.

                                  15

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Community Impact Analysis

This task is designed to identify potential  impacts  on local  community
economies where the impacted plant might represent a major source of
employment and income.   This analysis is based on a  knowledge of the
location of plants, particularly threatened  plants,  and a  general  under-
standing of the economic base of those communities and the relative
importance of threatened plants to local economies.

Balance of Payments Impact Analysis

Balance of payments impact analysis deals with those products that have
competitive positions with regard to imports and exports.   The analysis
considers whether or not the estimated price changes would further
hinder competitive positions of leather tanners with regard to exports
or increase foreign imports.  Where important, estimates on the amount
of trade that potentially could be impacted  and total trade levels are
presented.

Other Impact Analysis

Other potential impacts may be created by the imposition of the waste
management regulations.  This will likely be unique  to given industries
requiring a case-by-case approach.  An illustration  of the possible type
of impact would be a plant that produces a critical  intermediate, an
input for other industries.  The loss of this plant  or large price in-
creases could produce serious backward or forward effects  on producers
or consumers.  To the extent additional impacts are  identified and are
important, these will be noted.
                                 16

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                    III.   STRUCTURE OF THE INDUSTRY
The Census of Manufactures defines the Leather Tanning and Finishing
Industry (SIC 3111) as an industry comprised of establishments pri-
marily engaged in tanning, currying, and finishing hides and skins into
leather.  The Census classifies the Leather Tanning and Finishing Indus-
try into three types of establishments.   These include:

       1.   "Regular tanneries" - the regular tannery purchases raw
           materials, employs production workers in the plant to
           tan, curry and finish hides and skins, and sells the
           finished product.   In effect, this type of establish-
           ment performs all  of the usual manufacturing functions
           within one organization.

       2.   Converter - the converter typically performs only the
           entrepreneural functions of the manufacturing concern
           such as buying raw materials, and arranging processing
           with outside factories, i.e., contract tanneries for
           the production of the finished leathers.  The actual
           tanning and finishing of hides and skins is done on
           contract by the contract tanneries.  Thus these establish-
           ments do not generate solid waste standards.

       3.   Contract tanneries - the contract tanner employs production
           workers in his own establishment to process materials owned
           by converters, makes products to specification but does not
           become  involved in the sale of the finished product.

  It should be noted, however, that the above classification is not mutually
  exclusive since some firms in the industry act as both regular tanners,
  and leather converters or as regular tanners and contract tanners.

  The Census identifies establishments that tan leather, tan and finish
  "eather, and only finish leather.  These establishments, furthermore,
  (_re on«_  if six types of members of the Tanning;  Industrial Leather Goods;
  and Shoe Industrial Group, SIC 31A.  The industrial group members include
  the following four-digit industries:

        . 3111 Leather Tanning and Finishing
        . 3131 Boat and Shoe  Cut, Stock  and Findings
        . 3142 House Slippers
        . 3143 Men's Footwear except athletic
        . 31^4 Women's Footwear except athletic
        ,. 3149 Footwear, except rubber N.E.C.


                                    17

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Within the SIC 31A industrial  group, the leather tanning industry has  the
largest number of establishments,  fourth highest number of employees  and
third largest value of shipments of the six four-digit industries listed
above.
                      A.   Industry as a Process


The Leather Tanning and Finishing Industry includes processing plants
primarily engaged in processing the raw animal  hide into usable finished
leather.  As mentioned previously, the industry is classified into  three
types of establishments:   (1) regular tanneries, (2) converter, and (3)
contract tanneries.

The various categories of tanneries help to provide an important link
between the raw hides and the Finished Leather Products Industry, by
converting the raw hides  and skins into usable leather.  Figure 2
illustrates many of the interrelationships of the Leather Tanning and
Finishing Industry with regards.to major supplier and customer industries.
As is shown, the Leather Tanning and Industrial Leathers account for approx-
imately 46 percent of the Meat Packing Industry's hides and skins,  with
the remaining 45 percent being exported.  These hides represent approximately
39 percent of the Leather Industry's total expenditures.  Other expenditures
of the Leather Industry include 42 percent of the total expenditures for
materials, chemicals and processing costs and 19 percent for materials  and
services provided by other establishments classified in the Leather Industry.

Thirty two percent of the Leather Industry's total sales are to
establishments which produce other leather products, 19 percent are to
other establishments in the Leather Industry and 49 percent of the  Industry's
sales are to the footwear, except rubber, manufactures.  The sale of leather
to the footwear manufacture represent 40 percent of the footwear manufactures'
total expenditures.

Other interrelationships  are also depicted in Figure 2.


                 B.  Characteristics of the Industry


The Leather Tanning and Finishing Industry consists of a wide diversity
of types of firms.  Firm ownership ranges from family-owned companies  and
closely held corporations to divisions of relatively large conglomerations.
Tanneries vary considerably in size as well as tanning techniques for  tanning
a variety of hides and skins into several distinct leathers.

Number of Tanneries

The U.S. Department of Commerce has reported the number of establishments
in the Leather Tanning and Finishing Industry as follows:
                                  18

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vo
         Meat  Packing
            Industry
         Hides  &  Skins
           Materials,
           Chemicals,
         Processing  Cost
             N.E.C.
              Misc.
             Rubber
            Products
       o
                                               Leather
                                             Tanning  and
                                             Industrial
                                              Leathers
                                 ©
                                               Other
                                              Leather

                                             Products
                                                       Footwear

                                                        Except

                                                        Rubber
                                                                                        Exports
                                                                                     of Salt Cured
                                                                                         Hides
Percent leather industry's expenditures and sales.

Figure 2.  Leather Tanning and Finishing  Industry, Sales and Expenditures.
Source:  U.S. Department of Commerce, Industrial  Outlook,  1975.
  Exports
of Leather
 Products
                                                                                          Personal
                                                                                         Consumption
                                                                                        Expenditures

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           Year                       Number of Establishments

           1963         '                       525

           1967                                519

           1972                                517
           1973                                490
           1974                                484
           1975                                441
           1976                                430

Table l shows  the total number of establishments in the Leather Tanning
and Finishing Industry by  classification  for 1967 and  1972.   The  Census has
used the primary plant operation  as  the delineating  classification  criteria.
If the direct wage and salary payments for one category were  less than the
payments for the second, the plant was classified according to  the  category
in which the higher amount of wage and salary payments were made.   In  1972,
58 percent of the establishments  were classified as  tanneries,  15 percent as
converters, and 27 percent as contract tanneries.

A tabulation by the Tanners' Council  of America indicates  a total of 431
plants (including converters) in  the  industry as of  30 June,  1973.   Their
records also indicate a total of  19  plants (establishments) have  ceased
operations between the period of  1 July 1973 and 31  December  1975.   This
would result in 412 plants being  in  operation at the end of 1975.   It  is
believed that the difference in the  number of plants reflects a difference
in method of classification with  the  Department of  Commerce data  including
miscellaneous small operators, many  of which would  be  classified  as taxi-
dermist by the Tanners' Council rather than tanners  or finishers.

All the establishments reported by the Department of Commerce would not be
impacted by solid waste treatment requirements. Based on  industry  surveys,
industry contacts, and segmentation  of DOC data, the probable number of
solid waste generating plants is  estimated at about 250.  Those not impacted
would include brokers, warehousers,.  hobbyists and  taxidermists to  name a
few.  The segmentation of the total  industry is given  below for all SIC
3111 plants.

                   Segmentation of SIC 3111 - 1976

       Segment                       No.  of Establishments (Plants)

Wet tanneries                                  188
Dry tanneries  (Leather Finishers)               60
     Plants w/solid waste                               248

Leather Converters                              65
Other Non-production Plants*                 ^ 130
     Plants w/o solid waste                           ^ 195

TOTAL - SIC 3111                                        430

*  Includes brokers, dealers, sales organizations, warehousers, taxidermists,
   hobbyists, and others.

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    Table 1-  Total number of establishments  in  the  Leather  Tanning
              and Finishing Industry by classification


                                                                   Contract
                              Total      Tanneries     Converter     Tanneries


1967

No. of establishments          519         314           70           135
With 1 - 19 employees          261          163           52            46
With 20 - 99 employees.        171          91            13            67
With 100 employees or more      87         60            5            22

1972

No. of establishments          517         301            76           140
With 1 - 19 employees          294         154           64            76
With 20 - 99 employees         148         89            8            51
With 100 or more employees      75         58            4            13


Source:  U.S. Department of Commerce,  Census  of  Manufactures,  1967 and 1972.
                                 21

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Size of Tanneries

Based on number of employees, an indication of plant size is available from
the Census of Manufactures (Table 1).  These data are restricted to the
years 1967 and 1972, but are reflective of general  industry characteristics.
Plant size appears to have remained relatively constant between the period
of 1967 and 1972.  In 1972, 57 percent of the total plants had less than 19
employees.  This is an increase from 50 percent in  1967.  In 1972, 29 percent
of the plants employed between 20 and 99 employees  and 14 percent had 100
employees or more.

However, tanneries of concern to this study will be reported in a different
fashion.  Instead of utilizing number of establishments for various employ-
ment groups, the tanners are disaggregated according to various size cate-
gories of their daily capacity expressed in cattlehide equivalents.  These
categories, as well as the number of associated wet tanneries, are depicted
below:

  Daily Capacity                Number of Tanners                 Percent
  .(cattlehide
   equivalents )V

  Less than 300                        46                           19
    300 - 699                          80                           32
    700 - 1,199                        64                           26
  1,200 - 1,999                        33                           13
  2,000 or more                        25                          	5
                                      248                          100
]_/ One cattlehide equivalent equals 40 square feet of leather.


As can be seen, the tanners that are potentially impacted are somewhat more
evenly distributed according to size than are all the establishments of the
Census data, tanners and non-tanners.  However, as was the case for the Census
data, the smaller size categories do represent a larger portion of the tan-
neries than the larger categories.

Types of Major Products

Six major categories of animal skins are used today in addition to imported
rare skins such as kangaroo, etc.  They are as follows: cattlehides, kipskins
and calfskins; sheep and lamb skins; goat and kidskins; pigskins; horsehides;
and deer and elk skins.

The products of the industry can be identified in traditional terms based
upon primary raw materials employed and end use.
                                   22

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CATTLEHIDES:
       CATTLE SIDE LEATHER.   This is the principal  product  of  the  industry
       which accounts for approximately 67% of total  industry  sales.   End
       use includes—shoe uppers, linings,  garments,  gloves, sporting  goods,
       handbags,  small  leather goods,  and waist belts.   Side leather is
       primarily  chrome tanned.

       CATTLE SIDE SPLIT LEATHER.  Cattle side split  leather is  a  by-product
       of hides which is not processed in full thickness.   Used  for shoe
       uppers, linings, insoles,  work gloves,  small leather goods, handbags,
       protective industrial clothing.  Chrome tanned;  processed by side
       leather tanners  or sold to "split tanners"  for finishing  into
       specialized products.

       SOLE LEATHER.   Almost entirely vegetable tanned.   Major use is  for
       shoe soles.  Secondary uses include  welting, counters,  box  toes,
       waist belts.

       CATTLE SIDE PATENT LEATHER.  Sub-class  of chrome tanned cattle  sides
       finished with special compounds (polyurethanes)  for  glossy  surface.

       KIP SIDE LEATHER.  Leather tanned from  kips  which are small hides,
       intermediate between calfskins and cattlehides.   Used almost entirely
       for shoe uppers.

       UPHOLSTERY LEATHER.  Mainly vegetable tanned;  some chrome retannage.
       End use includes automotive and furniture upholstery.

       HARNESS AND SADDLERY LEATHER.  Composite group of the same  plants
       but possessing different characteristics useful  for  various parts
       of equine  equipage or related uses.   (Collar,  harness,  skirting,
       latigo, bridle,  etc.)  Also used for holsters, gun cases, etc.

       SPORTING GOODS LEATHER.  Combination tannages  of chrome,  vegetable,
       alum, glutaraldehyde used for footballs, baseballs,  baseball gloves
       and laces.

       BAG, CASE  AND STRAP LEATHER.  Trade  description for  specialized
       group of leathers which are vegetable,  chrome  and combination
       tanned.  End use includes luggage, briefcases, small leather goods,
       decorative items, equipment cases, straps,  and heavy bookbinding.

       MECHANICAL LEATHER.  Vegetable, chrome  and impregnated  leather  for
       industrial uses  including belting, gaskets,  washers, seals  for  equip-
       ment.

       CALFSKINS.  Chrome tanned leather from  skins of immature  cattle used
       for shoe uppers  and handbags.  Volume is in  sharp decline due  to
       shrinkage  of raw material  supply.
                                    23

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SHEEP AND LAMB SKINS:

       Second largest raw material  category.   Chrome  alum,  oil  and  combina-
       tion tannages for garments,  gloves,  shoe  uppers  and  linings,  handbags
       and wallets, bookbinding and chamois.

GOAT AND KID LEATHER SKINS:

       Chrome tanned in smooth or suede finish used for shoe  uppers  and
       linings.
PIGSKIN:
       Vegetable or chrome tanned shoe uppers,  gloves,  garments,  and small
       leather goods.
HORSE HIDES:
       Chrome and vegetable processed for shoe uppers, garments,  baseballs.
       Cordovan is included in this group.
DEER AND ELK HIDES:

       Chrome and vegetable tanned for gloves, garments,  and to a minor
       degree for shoe uppers (buckskin).

MISCELLANEOUS AND EXOTIC LEATHERS:

       Aggregate volume is minor and the number of producers in the U.S.  is
       less than 10.  Products include Kangaroo for athletic shoe uppers,
       reptile for shoe uppers, belts, and small leather goods, Peccary and
       Carpincho for gloves.

In summary, cattlehides are the dominant raw material of the industry with
the major products of Cattle Side leather, Sole leather, Upholstery, Garment
and Bag, Case and Strap leathers.  Sheep and Lamb skins are the second and
much smaller raw material base yielding mainly garment and glove leather,
lining and shoe stock, chamois and leather for small leather goods.

Value of Shipments

Value of shipments and other receipts of the Leather Tanning and Finishing
Industry in 1972 totaled $1,059.5 million.  This included shipments of
tanned and finished leather  (primary products) valued at $1,018.2 million,
shipments of other products  (secondary products) valued at $11.2 million,
and miscellaneous receipts  (mainly resales) valued at $30.1 million.

Estimates of the 1977 value of shipments are expected to total $1,730
million, 8.1 percent above  the shipments of 1976 and 38.7 percent above
the 1972 value of shipments  (Table 2).  Historically the value of
shipments have fluctuated from year to year, however, the overall average
annual increase has been 5.1 percent since 1960.
                                 24

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    Table 2.   The Leather Tanning and Finishing  Industry,  Value of
                     Shipments, 1960 to 1976
                          Value of                   Percentage
Year                      shipment                     change
                          (mil. $)                       (Ij

1960                       790.7
1961                       761.1                         -3.7
1962                       765.9                         -0.6
1963                       758.4                         -1.0
1964                       783.6                          3.3

1965                       856.7                          9.3
1966                       940.5                          9.8
1967                       870.1                         -7.5
1968                       877.9                          0.9
1969                       853.9                         -2.7
1970
1971
1972
1973
1974
1975
1976 */
1977 */
794.4
838.3
1,059.5
1,082.0
1,075.5
1,184.0
1,600.0
1,730.0
-7.0
5.5
26.4
2.1
-0.6
10.1
35.1
8. 1
*/
-  Estimated
Source:  Department of Commerce, Bureau of the Census and Bureau  of
         Labor Statistics,  BDC,  U.S.  Industrial Outlook, 1977.
                                25

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Shipments of tanned and finished leather (primary products)  in  1972  repre-
sented 99 percent (specialization ratio) of the industry's  total  product
shipment.  The industry specialization ratio in 1967 was  98 percent.   Second-
ary products shipped by the industry in 1972 consisted mainly of  boot and
shoe cut stock and findings ($2.5 million).

Shipments of tanned and finished leather from establishments classified in
industry SIC 3111 in 1972 represented 99 percent (coverage  ratio)  of these
products valued at $1,026.4 million shipped by all industries.  In 1967,
the coverage ratio was also 99 percent.  Thus for all practical purposes,
it can be concluded that all establishments of tanning and  finishing leather
are classified in industry SIC 3111.

Location of Tanneries

Leather tanning and finishing establishments tend to be concentrated in
the Northeastern region of the country.  As shown in Table  3, 62  percent
of the total number of establishments were located in the area  in  1972.
Massachusetts ranked first, in total number of plants; New  York second; and
New Jersey third, with 25, 19, and 8 percent respectively.

The second area of concentration is the East North Central  region  with
Wisconsin reporting 22 plants or 4.3 percent of the total.   Other states
of importance in this region include Ohio, Illinois, and Michigan.  The
remaining plants are scattered widely throughout the United States.

Historically, tanneries were established where there was  an adequate supply
of hides, water and tanning materials (i.e., tree bark),   This  began in New
England and the Mid-Atlantic states and followed the cattle herds  west,
though with a long time delay.  As indicated above, tanneries are  still
located in New England and Chicago as well as in the dairy  country of
Wisconsin.  However, with the recent spatial dispersion of slaughter facili-
ties away from the traditional centers such as Chicago and Kansas  City, it
is expected that in time new tanneries will follow the same trend and locate
near the supply of hides.
The locations of all the wet and dry tanneries; excluding converters,
brokers, etc.; are difficult to pinpoint as adequate data are  not
presently available.  However, based on survey responses approximately
62 percent of the wet and dry tanners, are located in the New  England
states; 8 percent were located in the Southern states; 21 percent are
located in the Midwest; and the remaining 9 percent are located in
the Western and Southwestern states.

If these percentages are extrapolated for all 248 wet and dry  tanneries, the
locational breakdown appears as follows:

      Area                    Number of Tanneries      Percent  of all Tanneries
                              Wet    Dry    Total
      New England             101    52      153                 61.7
      South                    19     2       21                  8.5
      Midwest                  47     5       52                 21.0
      West and Southwest       21    _]_       22                  8.9
          Total               188    60      248                100.0

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                         Table 3.
Location of Leather Tanning  and Finishing establishments by primary state
                    and region, 1967, 1972
1967
;egion
Jortheast Region
•lew England Division
Maine
New Hampshire
Vermont
Massachusetts
Other
liddle-Atlantic Division
New York
New Jersey
Pennsylvania
North Central Region
East North Central Division
Ohio
Illinois
Michigan
Wisconsin
Other
West North Central Division
Minnesota
Missouri
Iowa
Other
South Region
South Atlantic Division
Delaware
Maryland
Virginia
West Virginia
North Carolina
Georgia
Other
East South Central Division
Kentucky
Tennessee
Other
West South Central Division
Texas
Other
West Reoion
Pacific Division
California
Other
TOTAL
Total Industry
Number Percent
183
16
18
1
146
2
176
108
48
20
74
12
19
10
30
3
13
2
6
NA
•5
26
6
2
4
,4
2
2
6
12
3
9
9
7
2
26
15
11
519
35.3
3.1
3.5
0.2
28.1
0.4
33.9
20.8
9.2
3.9
14.2 .
2.3
3.6
1.9
5.8
0.6
2.6
0.4
1.2
NA
1.0
5.0
1.1
0.4
0.8
0.8
0.4
0.4
1.1
2.3
0.6
1.7
1.7
1.3
0.4
5.0
2.9
2.1
100.0
Establishments with
20 or More Employees
Number
93
14
15
1
62
1
68
30
25
13
51
7
12
5
24
3
7
1
5
NA
1
18
6
1
4
4
2
1
0
10
3
7
2
2
0
9
8
1
258
f>ercent
36.0
5.4
5.8
0.4
24.0
0.4
26.4
11.6
9.7
5.1
19.8
2.7
4.7
1.9
9.3
1.2
2.7
0.4
1.9
NA
0.4
7.0
2.3
0.4
1.6
1.6
0.7
0.4
3.9
1.2
2.7
0.8
0.8
3.5
3.1
0.4
100.0
1972
Total Industry
Number
324
163
15
19
1
128
161
98
43
20
84
62
8
19
8
22
5
22
4
NA
6
12
59
27
2
1
5
4
5
2
7
12
3
8
1
20
15
5
50
42
33
9
517
Percent
62.7
31.5
2.9
3.7
0.2
24.7
31.1
19.0
8.3
3.9
16.2
12.0
1.5
3.7
1.5
4.3
1.0
4.2
0.8
NA
1.1
2.3
11.4
5.2 *
0.4
0.2
1.0
0.8
1.0
0.4
1.4
2.3
0.6
1.5
0.2
3.9
2.9
1.0
9.7
8.1
6.4
1.7
100.0
Establishments with
20 or More Employees
Number Percent"
132
78
10
14
1
53
54
26
15
13
48
39
4
10
4
19
2
9
2
NA
4
3
27
14
2
1
3
4
2
1
1
10
3
7
NA
3
3
NA
If
i;
13
1
223
59.2
35.0
4.5
6.3
0.4
23.8
24.2
11.7
6.7
5.8
21.5
17.5
1.8
4.5
1.8
8.5
0.9
4.0
0.9
NA
1.8
1.3
12.1
6.3
0.9
0.4
1.3
1.8
0.9
0.4
0.4
4.5
1.3
3.2
1.3
1.3
7.2
C.3
5.8
0.5
100.0
Source:   U.S. Department of Commerce, Census of Manufactures. 1967 and 1972.
                                                          27

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Age of Plants and Level of Technology

The Leather Tanning and Finishing Industry can be described as  having
basically old plants in terms of actual  brick and mortar with slightly
over 70 percent of the plants 50 years of age or older.   From the member-
ship records of the Tanners'  Council, the age of tanning and/or finishing
leather plants, excluding converter, is  as follows:

                                        Percent of Members

       Less than 10 years                        1
       10-15 years                               1
       15-20 years                               3
       20-30 years                               5
       30-50 years                              19
       Over 50 years                            71
               Total                           100

Although the majority of industry units  are in old buildings, a substantial
number of plants have been rebuilt, modernized and re-equippped at a cumula-
tive cost approaching the capital investment required for new plants.   Most
plants have made major changes since 1960, although technology  changes over
the last fifty years have been minimal.


               C.  Importance of Integrated Capacities


The industry is not characterized by any appreciable integration either
back to the raw material supply or forward to finished or fabricated
leather products.  There is,  in fact, less integration today than several
years ago when two major packers owned tanning facilities and four leading
shoe manufacturers operated tanneries.  It is estimated that the sales
volume of tanning or finishing establishments integrated with raw material
producers is very small, less than five percent of gross annual volume.
Leather tanning facilities owned or operated by manufacturing companies
account for equally as small  percentage of leather sales or value.


                     D.  Level of Diversification
The Census of Manufactures shows the Leather Tanning and Finishing Industry
with a very high specialization ratio of 99 percent for 1972.  This indi-
cates that 99 percent of sales are in the primary SIC code.  The typical
production unit of the industry is not diversified for two main reasons.
First, tanning equipment and processes are specialized and non-interchange-
able in terms of raw materials or end product.  Hence, most plants have
confined production to a very limited range of product.
                                    28

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Second, shoe manufacturing has been and still  is  the  principal  consuming
industry.   In 1962, shoes accounted for 83 percent of all  leather used.
By 1972 this ratio had declined to 74 percent,  and tanneries  were seeking
to diversify output.   Cattle side leather plants  entered the  garment
leather market and sought outlets in waist belts, handbags  or small
leather goods. 'However,  this trend does not reflect  diversification of
basic product line.  It indicates rather, an effort to adapt  available
plants and equipment to moderately different needs of end  uses  other than
shoes.

A further observation is  pertinent.  Tanning machinery and equipment
cannot be adapted for any purpose other than treating hides and skins.
It is fixed capital which must be written off at  scrap value  in the
absence of demand for used machines.
                    E.   Employment Characteristics

Employment

Total employment within the Leather Tanning and Finishing Industry has
decreased by about 19 percent since 1965, declining from 32,000 employees
in 1965 to 26,000 employees in 1976 (Table 4).  However, employment
was up in both 1975 and 1976 from an eleven year low of 22,000 in 1974.
Of the total employees  in 1976, production workers represented approximately
88 percent or about 23,000 individuals.   For the period 1965 to 1974,  the
number of production workers in the industry had declined by over 34 per-
cent, from 27,900 to 18,300 people.

Modest increases have occured in the last two years and the number of
production workers in 1976 is 25 percent over the low 1974 level.  The
Leather Tanning Industry employs unskilled, semi-skilled and skilled
labor dependent on the  requirement of the task being performed.  Tanneries
can be either union or  non-union shops with the number of tanneries in
each category being about equal.

Production workers average approximately 1,900 hours per year which repre-
sents 230 to 250 employed days per year.  With respect to the production
workers productivity, Table 4 depicts the average number of hours
required to produce one cattlehide equivalent.  As shown in the table,
this productivity measure has varied from year to year but has remained
reasonably close to 1.7 hours per hide since 1965.

Level of Wages

In 1974, the latest data available, the total industry's payroll amounted
to $194.3 million.  The total wages paid to production workers for the
same year totaled $141.4 million or about 73 percent of the industry's
total payroll.
                                  29

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                               TabTa 4.  The Leather Tanning and Finishing Industry,
                                           Employment Characteristics
CO
o

All Employees
Year

1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
Number
(1000)
32.0
32.7
30.7
31.1
28.8
24.1
24.5
25.7
23.4
22.0
23.0
26.0
Payroll
(mil. $)
180.0
189.2
186.4
196.0
188.1
•171.5
183.9
200.0
186.5
194.3
N.A.
N.A.


Number
(1000)
27.9
28.2
26.4
26.7
24.4
20.4
20.7
22.1
19.8
18.3
20.0
23.0


Wages
(mil. $)
139.0
144,4
142.5
151.2
142.8
129.8
137.6
151.3
138.2
141.4
N.A.
N.A.


Annual
Hours/Worker
(Hours)
2,039 .
2,039
2,000
1,985
1,943
1,980
1,976
1,896
1,909
1,934
N.A.
N.A.
Juction Workers •
Annual
Wages/Worker
(Dollars)
4,982
5.121
5,398
5,663
5,852
6,363
6,647
6,846
6,980
7,727
N.A.
N.A.


Ave. Hourly
Rate
(Dollars)
2.44
2.51
2.70
2.85
3.01
3.21
3.36
3.61
3.66
4.00
N.A.
N.A.


Ave. Hours Per
Equiv. Hide
(Hours)
1.74
1.78
1.71
1.66
1.67
1.56
1.62
1.70
1.79
1.78
N.A.
N.A.
       N.A.  1s defined as Not Available.
       Source: U.S. Department of Commerce, Bureau of the Census.

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Annual wages per production worker averaged $7,727 in 1974 which represented
an increase of 55 percent over the last 10 years.   During this same period,
the average hourly rate increased by 64 percent from $2.44 per hour in 1965
to $4.00 per hour in 1974.


                     F.  Ownership Type and Size


The Leather Tanning and Finishing Industry consists of a wide diversity
of types and sizes of firms.  Firm ownership ranges from family owned
companies and closely held corporations to divisions of large conglomerates.
However, the majority of the tanneries would fall into the family-owned
or closely held corporation group.  This is attributable to the fact that
most  tanneries are relatively small and were established years ago by either
a family or a small gorup of individuals who have remained in control of
the operation.


                        G.  Industry Segments


The Leather Tanning and Finishing Industry has traditionally been segmented
by type of leather manufactured such as cattlehide leathers, sheep and lamb
skins, goat skins, etc.  Most of the industry production data are given in
these terms.  However, categorization of the industry by manufacturing pro-
cesses is more appropriate for evaluating the impact of solid waste handling
on the industry since a major factor affecting the waste production in the
leather industry is the type of manufacturing process used to convert the
various types of animal skins to finished leathers.

The following material discusses industry segments using two taxonomies:
(1) conventional industry segments, and (2) categorization of plants by
manufacturing process.

Conventional Industry Segments

Cattlehide leathers accounted for 81.3 percent of the total 1972 production
in the leather tanning and finishing industry.  The major use of cattlehide
leathers is side and patent leather used for shoe uppers.  This accounted
for 48 percent of total leather or 59 percent of the cattlehide processed.
Sheep and lamb skins were the second most important with approximately 10
percent of the 1972 production (Table 5).

Categorization of Plants by Type of Manufacturing Process

For the purposes of evaluating solid waste handling methods, the leather
Tanning and Finishing Industry has been divided into seven major categories
These categories generally correspond to those developed by SCS Engineers
principally by similarities in process and waste loads.   The industry
categories are:
                                    31

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      Table  5.  Percent of production and employment by conventional

                        industry segment, 1972.
Industry Segment
Cattlehide Leathers
Side and Patent
Sole and Belt
Upholstery
Split Leather
Harness
Bag, Case & Strap
Other I'
Calf Leather
Goat and Cabretta
Sheep and Lamb
Pig
All Other U
Converters
Percent
of industry
production
81.3
47.8
9.4
4.7
10.9
0.1
1.8
6.6
1.1
2.3
10.3
4.6
0.4
n. a.
100.0
Percent
of industry
employment
80.7
52.6
11.4
6.9
5.3
4.5
2.0
1.8
7.7
4.5
3.3
n.a.
100.0
—  Includes sporting goods and mechanical

2/
—  Includes horse, kangaroo,  deer,  reptile and exotic types.


   Source:  Tanners' Council of America, Inc.
                                 32

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      1.   Cattlehide-chrome—a tannery that primarily processes raw or
          cured cattle or cattle-like hides into finished leather using
          chrome tanning.  Hide hair can either be chemically dissolved
          or saved.

      2.   Cattle-nonchrome (primarily vegetable)—a tannery that primarily
          processes raw or cured cattle or cattle-like hides into finished
          leather using less than 20 percent (by hide weight) chrome tanning;
          includes vegetable, and also alum, syntans, oils, and other methods
          and their combinations.  Many of these plants will not be impacted
          by hazardous waste management regulations.

      3.   Cattle-to-blue--a tannery that primarily processes raw or cured
          cattle or cattle-like hides through the blue-tanned state only,
          with no retanning or finishing operations,  and uses chrome
          tanning.

      4.   Cattlehide-splits--a tannery that primarily processes splits or
          previously tanned hides and/or skins into finished leather, the
          major wet process consisting of trimming, resplitting, retanning,
          coloring, and fat-liquoring.

      5.   No beanhouse (NB) tannery—a tannery that primarily processes
          hides and/or skins, with the hair previously removed,, into
          finished leather using either chrome or nonchrome tanning
          methods, primarily includes pickled sheepskins and cattlehides
          and pigskins.

      6.   Shearlings--a tannery that primarily processes raw or cured
          sheep or sheep-like skins, with the wool or hair retained on
          the hide, into finished leather using chrome or nonchrome tanning;
          or, a wool pullery—a plant that processes  hair-on raw or cured
          sheep or sheep-like skins by first removing the wool and then
          pickling the skin for use by a sheepskin tannery (Category 5).

      7.   Leather finishers—an establishment that receives unfinished
          leather to which it applies a finish and may also buff to remove
          imperfections; does not perform any other tanning functions;
          normally performs on a contract basis offering a service to
          customers.

A brief description of the major processes are given  here.  More detailed
descriptions are available in published technical descriptions of the
tanning and finishing processes.

The major processes are:

      1.   BEAMHOUSE

          This is a generic term for all the initial  stages of process
          after raw hides and skins are received at the tannery.  The
          beamhouse entails large use of water and is a major source of
          tannery waste loads regarding sludge.
                                   33

-------
      2.   TANYARD

          The series of steps by which putrescible hides and skins are
          converted into stable, non-putrescible leather utilizing
          aqueous solutions containing various chemical  agents.

      3.   RETANNING, FAT LIQUORING AND COLORING

          In these process stages the specified physical properties of
          leather are adjusted and set prior to surface  treatment.  Waste
          loads are substantially reduced from the previous steps and
          processes.

      4.   FINISHING

          Devoted largely to surface appeal and characteristics.   Most
          important characteristic with respect to waste loads are trimmings
          and buffing dust.

Table 6 depicts an estimation of the number of tanneries by size  and
by general categories.  Because of the limitations of available data no
further breakdown of the tanneries by category could be  realistically
attempted.
                                   34

-------
                             Table 6.  The Leather  Industry,  Wet  Tanners  by  Type and Size
to
in

Cattle
Industry Cattle Non Chrome Cattle
Size Total Chrome (primarily Splits
vegetable) (Retan)
(Daily Capacity
in Cattlehide
Equivalents)
0-299 45 15 92
300-699 80 27 8 2
700-1,199 64 21 4 7
1,200-1,999 32 22 5 4
2,000 or more 27 20 2 0
Total 248 105 28 15
Shearling
Cattle to Chrome Leather
Blue (includes other Finishers
sheepskin) (Dry)

16 3
7 1 35
7 0 25
0 1
320
3 32 5 60
         Source: Industry Survey

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           IV.  FINANCIAL CHARACTERIZATION OF THE INDUSTRY


Information reflective of the financial characteristics of the Leather
Tanning and Finishing Industry is particularly difficult to obtain.  The
industry primarily consists of family-owned businesses or relatively small
privately-held corporations.  As such, published information regarding the
financial position of the industry are not readily available.  Limited
data are available from the Internal Revenue Service but these data are
relatively old (1972-74) and represent the aggregated Leather and Leather
Products Industry.  Some more recent data are available from Robert Morris
Associates' Statement Studies, but these represent financial information
from less than 40 different statements.

Information used to develop this chapter on the financial profile of the
industry draws on the above named sources where applicable.  Additional
information was obtained from the U.S. Department of Agriculture, U.S.
Department of Commerce, responses to the data collection portfolio as
well as discussions with persons knowledgeable of the Leather Tanning
and Finishing Industry.

                  A.  General Financial Situation

The Leather Tanning and Finishing Industry in the United States has
experienced a somewhat volatile financial situation in recent years.
The industry declined steadily in terms of number of plants, volume
and profits from the mid 60's on and reached a low in 1972 and 1973.
Beginning  in 1974 and continuing through 1975 and 1976, the  industry
experienced a much brighter market  situation.

The volatility of the industry varies  from firm to firm as well as
differing  for the various types of  tanneries and their respective leather
products.  Causes of this volatility are primarily resultant of changes
in the volume of leather sold as well  as competition from foreign countries
for both raw hides and the market for  leather and leather products.  With
the exception of 1968, the United States Leather Industry's  total produc-
tion declined every year from 1965  to  1974, decreasing from  32.7 million
cattlehide equivalents in 1965 to 20.0 million in 1974 (Table 7).
However, in 1975 and 1976 the industry did increase its annual production
over the previous year.  In 1975, the  annual production increased by 9.5
percent  over the  1974 quantity produced and 1976 production, equal  to  23.5
million  hide equivalents, increased 7.5 percent over the 1975 production.

As shown in Table 7, the industry's value of shipments have  been much
more volatile than the annual production quantitites.  From  1966 to 1970,
the industry's value of shipments generally declined.  Shipments then
increased  from 1971 to 1973; decreased in 1974; and then increased  in
1975 and 1976.  Again according to  the U.S. Department of Commerce
estimates, the value of shipments for  1976 are expected to  increase
from $1,184 million in 1975 to $1,600  million in 1976, an increase  of
35 percent.
                                    36

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     Table?.  The Leather Tanning and Finishing Industry, production and value of shipments, imports,
                and exports  in current and real dollars, 1965-1976.
Co


Year

Total industry
production I/
1,000 equiv
Value of industry
shipments £/
current
real 3/
Value of leather
imports I/
current real.
Value of leather.
exports
current
i,
real


1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
Sources:


32,697
32,252
30,861
31,884
28,388
25,941
25,267
24,661
21,062
19,998
21,894
23,526
I/ Tanners Council
. Edition.
2/ U.S. Department
857
940
870
878
854
794
838
1,060
1,082
1,076
1,184
1,600*
of America,

of Commerce
1,153
1,226
1,101
1,063
985
869
873
1,060
1,021
843
930
1,200*
Inc. , Membershi

, Annual Survey
67 90
75 98
68 86
81 98
86 99
87 95
83 86
139 139
127 120
125 107
88 69
.181* 135
p Bulletin Leather

39
42
42
45
42
37
43
67
83
102
140
139*
Industry Statistics,

52
55
53
54
48
40
45
67
78
88
110
104
1977

of Manufacturers and U.S. Industrial Outlook.
              3/  Real dollars based on Implicit GNP Deflator (1972=100).

              *   Preliminary

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The recent upturn in the economic condition may be attributed primarily
to the increase in consumer demand for natural  leather and leather prod-
ucts.  This has been dampened by the influence of foreign tanneries on
domestic supply of raw leather and further expansion of imported leather
products to the United States.

Over the past decade consumer acceptance of synthetics as a substitute
for leather particularly for womens1 and childrens'  shoes and handbags
has become particularly widespread.  Also the decline of leather soles
has dropped to 13 percent of the shoes manufactured in 1975.   As a
result a significant portion of the market previously held by leather
was lost to synthetic products.  During the past few years, consumers
have developed an increased appreciation for natural leather products.
Accordingly leather increased its share of the appropriate products'
market.  However, this increase was not totally absorbed by the United
States tanners as much of this increased demand was met by imported leather
and leather products.

As shown in Table 7, the value of leather imports steadily increased
from 1965 to 1971.  In 1972 the value of imports increased by 66 percent
over the value of imports in 1971.  Much of this increase was absorbed
by the increased demand created by the greater appreciation of leather
by consumers mentioned above.  After 1972, the value of leather imports
slowly declined with a significant, 29 percent, drop between 1974 and
1975.  But in 1376, imports rebounded to record levels, estimated to
value $181 million.  When these trends are compared to the total industry
production it becomes apparent the values of leather imports are to a
degree inversely related to the total industry production.  That is,
while the values of imports increased, the total domestic production of
the industry decreased.  Thus the Leather Industry's volume of production
has fluctuated in recent years with the major cause being competition
from foreign tanners.

                B.  Cost Structure of the Industry

Revenues

For 1976, the Leather Tanning and Finishing Industry had estimated shipment
valued at $1,600 million (Figure 3).  This estimate represents an in-
crease of about 35 percent over the value of shipment for 1975.  Histori-
cally the industry's values of shipments have fluctuated from year to year,
however, since 1970, shipments have increased for every year except 1974
at which time shipments decreased 9.4 percent over the value in 1973.

In addition to experiencing a general slump in production prior to 1975-
76, the real value of the industries production has declined noticeably.
From 1966, when the real value of shipments I/ was $1,225 million (Figure
3), real revenues nave fallen to as low as $843 million in 1974; a
31 percent decrease over eight years.  This decline in real terms mirrors
a decline.in production which is attributable to a variety of factors,
most significant being demand lost  to foreign tanners.
 I/  Value of Industry Shipment.;  t  where 1 = year
      Implicit GNP Deflatori
         (1972 = 100.0)             38

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OJ
            1700-


            1600-


            1500


            1400
       c
       (U
      £• w  1300'
      j= s-
      XI O
       C 'I-
       (U
       (O
1200-


noo-


1000-


 900-


 800-
                                                                    Current
                                                                       Value,
                                                                                          Trend
       Real Value
' •   \  (1972 $ =  100)
       \
                                                                                          Trend
                                                                             V
                      65    66    67    68    69    70     71     72     73    74    75    76
                                                    Year  19_

            Figure 3.   Value of industry shipments, leather tanning  and finishing industry, current and
                                           real dollars,  1965-1976.

-------
The 1976 value of shipment for the industry was based on  information  pro-
vided by 430 establishments.   This gives the value of shipment for the
average tannery to be $3.7 million with the average annual  production
being almost 60,000 cattle hide equivalents (Table 8).  This  compares
to an average value of shipments of $2.7 million in 1975,  $2.0 million  in
1972, and $1.7 million in 1967.  Average production per establishment
was 50,000 cattle hide equivalents in 1975, 48,000 in 1972, and 59,000
in 1967.

Variable Costs

Within the Leather Tanning Industry, variable costs represent approximately
80 percent of the total sales.  These costs include expenditures for  raw
hides and/or skins, labor, tanning materials, and miscellaneous other
direct costs.  According to a survey of the industry, hides and skins
represent 37.2 percent of the sales dollar, tanning materials, 14.3 per-
cent, labor, 15.1 percent and miscellaneous expenditures,  12.4 percent.
These sum to 79 percent of the sales, dollar..

The only time series available depicting the distribution  of  the sales
dollar is available from the Department of Commerce and is somewhat
limited in its disaggregation.  These data are shown in Table 9 and
as can be seen in the table, raw materials, primarily hides,  have
represented about 60 percent of the sales dollar.

Fixed Costs

Fixed costs are defined as those which do not vary with the level or  quantity
of production.  These include:

          Sales, general and administrative
          Plant and labor overhead
          Taxes and insurance
          Maintenance and repair

Data are not available to discuss each of the above costs separately,
therefore, fixed costs were grouped.  Fixed costs vary from firm to firm
however, they usually represent 10 to 15 percent of sales.

Interest is considered a fixed cost although it is somewhat influenced
by the total sales.  For the Leather Industry interest usually amounts
to 1 to 2 percent of sales.  As shown in Table 10, interest costs vary
with different sizes of operations.  Although there are exceptions, it
appears that the larger sized tanneries have a greater portion of their
sales dollar consumed by interest.

Depreciation is also considered a fixed cost.  Typically it represents
between 5 and 10 percent of the firms total fixed assets.  This would
represent an expected asset life between 10 and 20 years.
                                40

-------
   Table 8."  The Leather Tanning and Finishing Industry, total and per establisnment data,
                      selected years 1963 to 1976.

Item
Establishments
VALUE OF SHIPMENTS
Industry
Per establishment
VALUE ADDED
Industry
Per establishment
PRODUCTION
Industry

Per establishment
EMPLOYEES
Industry
Per establishment
Units
No.

$1,000
d.o.

d.o.
d.o.

1,000 equiv.
hides
d.o.

No.
d.o.

1963
525

758,000
1,440

273,000
520

31,325

60

31,400
60

1967
519

850,000
1,680

319,000
615

30,861

59

30,700
59
Year
1972
517

1,060,000
2,050

368,000
710

24,661

48

25,700
50

1975
441

1,184,000
2,685

N.A.
N.A.

21,894

50

22,000
50

1976
430

1,600,000
3,720

N.A.
N.A.

25,526

59

26,000
60
Source:   U.S. Dept. of Commerce and Tanners Council of America.

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    Table 9.   The Leather Tanning & Finishing Industry, Distribution of
               the Sales Dollar.

TOTAL
SALES


1965
1966
1967
1968
1969
1970
1971
1972
1973
Million
Dollars
856.7
940.5
870.1
177.9
853.9
794.4
838.3
1059.5
1081.5

Percent
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
RAW
MATERIALS
Million
Dollars
535.6
614.1
547.0
524.5
514.9
471.4
498.5
708.0
744.3

Percent
62.5
65.3
62.9
59.8
60.3
59.3
59.5
66.8
68.8
PAYROLL
Million
Dollars
180.0
189.2
186.4
196.0
188.1
171.5
183.9
200.0
186.5

Percent
21.0
20.1
21.4
22.3
22.0
21.6
21.9
18.9
17.3
OTHER INDIRECT
OPERATING COSTS,
TAXES & PROFITS
Mi 1 1 i on
Dollars
141.1
137.2
136.7
157.4
150.9
151.5
155.9
151.5
150.7

Percent
16.5
14.6
15.7
17.9
17.7
19.1
18.6
14.3
13.9
Source:  Department of Commerce, Bureau of the Census, Census of Manufacturers.
                                  42

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         Table  10.  The  Leather Industry,  Interest as  a Percent of Sales (Business Receipts).
co
ASSET SIZE ($000)
FISCAL
1968-69
1969-70
1970-71
1971-72
1972-73
1973-74
Source:
ZERO
YEAR ASSETS

0.18
0.43
0.00
0.29
0.47
Department of
OVER ZERO
UNDER 100

0.33
0.52
1.34
1.20
0.37
0,79
100
UNDER
250

0.42
0.43
0.82
0.98
0.66
Q.99
250
UNDER
500

0.52
0.55
0,64
0.77
0,48
0.75
500
UNDER
1000

0.48
0.36
0.56
0.54
0...64
0.79
the Treasury, Internal Revenue
1000 5,000
UNDER UNDER
5000 10,000

0.59 0.88
0.80 0.69
0.99 0.84
0.81 0.46
0,63 0..39
0.99 0.98
Service, Source
10,000
UNDER
25,000

1.37
1.66
1.27
1.58
1.74
Book of
25,000
UNDER
50,000

— —
—
—
—
1.53
50,000
UNDER
100,000

1.14
1.67
1.85
1.27
—
100,000
UNDER
250,000

1.60
2.45
2.61
1.36

INDUSTRY
TOTAL

0.69
0.84
1.03
0.84
0.83
1.03
Statistics of Income, Annual,
             Active Corporations with and without Returns.

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                    C.  Industry Profitability

The Leather Tanning Industry in the United States experienced some rather
difficult times during the early 1970's, particularly in 1972 and 1973.
This was the result of the rapid rise in the price of hides and the tre-
mendous increase in cattlehide exports.   Between 1970 and 1973, 31 tanneries
discontinued operations and total movement of cattlehides to tanners dropped
from 19.2 million hides in 1972 to 17.7  million in 1973.

Since 1973, the industry performance has been considerably brighter.
Demand for leather has been up and the long run picture appears to be
strong.  Industry production has increased in both 1975 and 1976, with
production in 1976 being the highest since 1972.  Because of higher pro-
duction and favorable leather prices, sales were at an all-time high in
1976 and profits were acceptable.  The outlook for 1977 is also favorable
but industry authorities are very cautious.

Net Profits on Sales

Net profits, before taxes, expressed as percentages of sales, are depicted
in Table 11 for the years between 1970 and 1975.  As can be seen in
the table prior to 1974, the industry's profits were relatively stable
but yet quite low.  As was explained above, 1973 was considered a parti-
cularly bad year for  the industry and accordingly profits that year
represent the poorest earned during the six year period.  The recent
increased demand for  leather products as well as the improvements in the
industry's raw hide supply are significant factors in the industry's
improved profitability during 1974 and 1975.

When the Leather Industry's profitability is viewed for various sized
operations it becomes apparent the medium and large tanneries tend to
be more profitable than the smaller operations (Table 12).  This may
reflect some economics of scale, however it should be noticed that the
profits of the largest size category in Table 12 are consistently less
than the next smaller size category.  Thus, while economies of scale
may be important, other factors  such as effective management may have
more influence.

Return on Investment

Consistent information regarding the industry's  return on investment is
difficult to obtain.  However as reported in Robert Morris, Statement
Studies, the industry's return appears to have been between 10 and 15
percent during the 1972 to 1974  time period.  In 1975, the industry's
return was determined to be 17.9 percent.
                                   44

-------
   Table 11.   The Leather Tanning  Industry  Profitability,  1970-1975.
Profits Before
Tax as Percent
Year of Sales

1970
1971
1972
1973
1974
1975 DPRA Survey
Rober Morris
1976
(%)
2.2
2.4
2.5
1.9
6.0
6.7
6,5
4.5
Percent Profits
Before Tax
to Worth
(%)
N.A.
N.A.
10.0
14.1
12.7
17.9
2CL,Q
15.5
Cash Flow
as Percent
Sales
(X)
4.7
4.0
4.4
2.9
N.A.
N.A.
N.A.
5.7
Source:   1970 & 1971, Department of the Treasury,  Internal  Revenue  Service,
                      Source Book of Statistics  of Income,  Annual

         1972 to 1976 Robert Morris Associates,  Statement Studies.  Annual

         1975, Information from a data collection  portfolio sent to the
               industry by DPRA
                                45

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        Table 12.  The Leather Industry, Net Profits before Tax by Asset Size, FY 1969-1973.
01
ASSET SIZE ($000)
FISCAL YEAR
1968-1969
1969-1970
1970-1971
1971-1972
1972-1973
1973-1974
ZERO
ASSETS

11.7
4.0
—
21.9
—
2.3
OVER ZERO
UNDER 100

-2.2
-0.0
-6.5
-4.6
—
-9.5
100
UNDER
250

1.7
1.2
-0.9
2.5
0.9
1,6
250
UNDER
500

2.1
2.1
0.1
-0.5
1.8
-1,1
500
UNDER
1,000

4.0
0.4
2.7
2.6
3.1
0..1
1,000
UNDER
5,000
-Percent
5.0
2.5
2.0
2.8
1.3
2,2
5,000
UNDER
10,000
of Net
7.5
3.8
5.1
1.7
1.4
1..4
10,000 25,000
UNDER UNDER
25,000 50,000
Caloc 	 ._
6.2
0.1
5.9
6.9
3.8
2,4 6,4
50,000
Under
100,000

7.7
4.5
4.8
6.1
1.5
»*T-~
100,000
UNDER
250,000

3.8
2,7
3.6
1.9
1.0
^^.
INDUSTRY
TOTAL

4.1
2.2
2.4
2.4
1.7
1.2
    Source:  Department of the Treasury, Internal Revenue Service, Source Book of Statistics of Income, Annual

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Cash Flow

Cash flow represents the cash that is actually available for distribu-
tion, retention or use in acquiring additional assets.  Utilizing data
represented also in Table 12, it has been determined that cash flows
as a percent of sales were relatively small during the period 1970 to
1973.  While data are not available for 1974 and 1975, it is probable
that the increased profits would result in substantially higher cash
flows.  A new Robert Morris Associates data series does show higher
cash flows in 1976 as compared to early data.

              D.  Financial Structure of the Industry

Assets

Leather Tanning and Finishing can be considered a raw materials oriented
industry as tanners must maintain relatively large quantities of hides
and skins which represent a major component of the firms' capital require-
ments.  As shown in Table 13, current assets have represented between
61 and 75 percent of the industry's total assets between 1969 and 1975.
This reflects the large capital requirement tanners incur to maintain
adequate supplies- of raw hides and skins as well as the capital represented
by in-process leather.

Contract tanners and finishers are the major exception to the above
general statement as they do not buy hides to process and only perform
a service for hide owners.  In their operations, tanning and finishing
materials and equipment would generate most of the capital  requirements.

Fixed assets of the industry represent the conventional elements in
every manufacturing or processing industry,  i.e., the plant, land and
equipment.  In terms of the total assets, fixed asset requirements are
relatively small.  This does not imply that the industry requires rela-
tively few fixed assets.  Instead it reflects the significant amount of
capital required for hides as well as the fact that most tanneries are
older facilities and accordingly the costs of the fixed assets are signi-
ficantly less than if they were recently acquired.

The  distribution of assets does vary between  the various sizes of tanneries,
As shown in Table 14, the smaller tanneries  reflect a  lower proportion
of the total assets as fixed assets than do  the larger tanneries.  This
may  be explained by the fact that the larger  facilities are  often newer,
or at least more modern, which represents capital expenditures propor-
tionately higher than those incurred by the older, smaller  facilities.

Liabilities

Liabilities of the Leather Tanning Industry have been classified into two
basic categories:  (1) current, or short term liabilities,  and (2) long


                                 47

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          Table 13. The Leather Industry Assets, Liabilities and Equity,.Selected Years
00



Assets
Current Assets
Fixed Assets
Total Assets
Liabilities and Equity
Long Term Debt
Current Liabilities
Net Worth
Total Liabilities &
Equity

1969

70
30
100
19
28
53

100
Source: 1968-1972, Department of

1970

66
34
100
17
32
51

100

1971

61
39
100
15
27
58

100
the Treasury,

1972

70
30
100
13
29
58

100
Internal

1973
-percent-
69
31
100
16
35
49

100
Revenue

1974

75
25
100
17
33
50

100
Service,

1975

69
31
100
18
28
54

100
Source

1976

67
33
100
19
35
46

100
Book of
Industry
response
1975

65
35
100
11
28
61

100
Statistics
                of Income, Annual.
                1973-1976, Robert Morris Associates, Statement Studies-Annual, 1974-1977.
                Response to industry data collection portfolio, 1975, Development Planning and Research
                Associates, portfolio sent to industry in 1976.

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                  Table  14.   The  Leather  Industry, Assets, Liabilities and Equity,
                                        by Asset Size, 1972
Under
100
Assets
Current Assets
Fixed Assets
Total Assets
Liability and Equity
Long Term Debt
Current Liabilities
Net Worth
Total Liability & Equity

78
22
100
22
67
11
100
100-
249

73
27
100
21
45
34
100
250-
499

76
24
100
11
36
53
100
500-
999

73
27
100
9
30
61
100
Asset Size ($000)
1,000- 5,000- 10,000- 25,000-
4,999 9,999 24,999 49,999

69
31
100
7
38
55
100

71
29
100
4
26
70
100

81
19
100
28
17
55
100
50,000- 100,000- In
99,999 249,999

52
48
100
17
13
70 -
100

66
34
100
21
15
64
100
Source: Department of the Treasury,  Internal  Revenue  Service,  Source  Book of Statistics of Income. 1971-72.

-------
term debt.  The industry has  maintained a much higher portion  (approxi-
mately two-thirds) of its total  liabilities  in the form of short term
liabilities as can be seen in Table 13.   These short term liabilities
typically represent accounts  payable,  unpaid wages, and minor  plant and
equipment maintenance and replacement  expenses.   When expressed as  a
percent of the total  assets,  current liabilities represent approximately
30 percent (Table 13).

Long term debt within the Leather Industry represents approximately 20
percent of the industry's total  assets and 40 percent of the industry's
total liabilities.  The somewhat low proportion of long term debt re-
flects the relative age of the industry as most of the facilities and
equipment were purchased many years ago and thus have been paid for
or at least represent a lower purchase price than obtainable today.

Most of the industry's long term debt  represents the debts of  a few
newer tanneries as well as debts incurred by older tanneries moderniz-
ing or expanding.          .   .                    .

When the industry's liability structure is viewed with respect to size
(Table 14) it becomes apparent the larger tanneries have a much more
sizeable long term debt proportion of total  liabilities than the smaller
tanneries.  Furthermore, the  larger tanneries maintain a relatively low
overall liability commitment (33 percent of total assets) than do the
smaller tanneries (67 percent of total assets).

Net Worth

The net worth of  the industry is defined as its total assets less its
total liabilities.  Thus the net worth represents what portion of the
industry's assets are owned by the industry.  Since 1969, the  net worth,
expressed as a percent of total  assets, has varied.  However,  it has
usually remained  near the 50 to 60 percent range.  These percentages
would result in a debt to equity ratio of 0.8 to 1.0.

Net worth, when viewed with regards to tannery size, appears to be
larger, when expressed in terms of total assets, for the larger sized
tanneries than for the smaller tanneries (Table 14).  This would
imply that the larger tanners are less dependent on creditors  for pro-
viding funds either for normal operations or capital improvements.
                  E.  Cost of Capital - After Tax
 Return on invested capital is a fundamental notion in U.S. business.
 It  provides both a measure of actual performance of a firm as well as
 expected performance.  In this latter case, it is also called the cost
 of  capital.  The cost of capital is defined as the weighted average of
                                 50

-------
 the cost of each  type  of capital  employed  by  the  firm,  in  general  terms
 equities and interest  bearing-liabilities.  There is  no methodology  that
 yields the precise cost of capital,  but it can  be approximated within
 reasonable bounds.

 The cost of capital  was determined  for purposes of this analysis by  esti-
 mating performance measures of the  industry.  The weights  of  the two
 respective types  of capital fpr the  Leather Tanning Industry  were  esti-
 mated at 39 percent debt and 61  percent equity.   The  cost  of  equity  was
 determined from the ratio of earnings  to net  worth and  estimated to  be
 12.3 percent.

 To determine the  weighted average cost of  capital, it is necessary to
 adjust the before tax  costs to after-tax costs  (debt  capital  only  in
 this case).  This is accomplished by multiplying  the  costs by one  minus
 the tax rate (assumed  to be 48 percent).   These computations  are shown
 below and result  in the estimated after-tax cost  of capital being  9.2
 percent.
                        Before        Tax        After        Weighted
 Item      Weight      Tax Cost      Rate      Tax  Cost        Cost

 Debt        .39          9.0         .48        4.7           1.8
 Equity      .61          --          —         12.3           7.5
                                                                9.3
          F.   Assessment of Ability  to Finance New Investment

The ability of a firm to finance new investment for hazardous waste manage-
ment or plant expansion is a function of several critical financial and
economic factors.  In general terms, new capital must come from one or
more of the following sources: (1) funds borrowed from outside sources;
(2) equity capital through the sale of common or preferred stock; (3)
internally generated funds—retained earnings and the stream of funds
attributed to depreciation of fixed assets.

For each of the  three major sources of new investment, the most critical
set of factors is the financial condition of the individual firm.  For
debt financing,  the firm's credit rating, earnings record over a period
of years, stability of  earnings, existing debt-equity ratio and the
lenders' confidence in  management will be major considerations.  New
equity funds through the sale of securities will depend upon the firm's
future earnings  as anticipated by investors, which in turn will reflect
past earnings records.  The firm's record, compared to others in its own
industry and to  firms in other similar industries, will be a major de-
terminant of the ease with which new equity capital can be acquired.  In
the comparisons, the investor will probably look at the trend of earnings
for the past five or so years.


                                   51

-------
Internally generated funds depend upon the margin of profitability and
the cash flow from operations.  Also, in publicly held corporations,
stockholders must be willing to forego dividends in order to make
earnings available for reinvestment.

The condition of the firm's industry  and general economic conditions are
also major considerations in attracting new capital.  The industry will
be compared to other similar industries in terms of net profits on sales
and on net worth, supply-demand relationships,  trends in production and
consumption, the state of technology, impact of government regulations,
foreign trade and other significant variables.   Declining or depressed
industries are not good prospects for attracting new capital.  At the
same time, the overall condition of the domestic and international
economy can influence capital markets.  A firm  is more likely to attract
new capital during a boom period than during a  recession.  On the other
hand, the cost of new capital will usually be higher during an expansionary
period.  Furthermore, the money markets play a  determining role in new
financing.

Although, these general guidelines are very important to the Leather Tanning
and Finishing Industry for assessing overall ability to finance new investment
options, they will not need  to be reviewed extensively regarding  hazardous
waste management.  The capital requirements for waste management will be
minimal and ability of a company to maintain profitability will be the  key
test in determining if the industry can adopt hazardous waste management
measures.
                                  52

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        Table 15.   The Leather Industry, Financial Situation


                                Robert Morris Associates*/      DPRAj/
                             1972197319741975197F   1975


Pre-tax return on sales (%)   2.5    1.9    6.0    6.5    4.5    6.7

Pre-tax return on investment
                             10.0   14.1   12.7   20.0   15.5   17.9

Debt to equity ratio          1.1    1.1    0.9    1.0    1.4    0.8

Current assets to current
  liabilities ratio           1.7    1.6    1.7    1.8    1.8    2.3


Sources:  I/  Robert Morris Associates, STATEMENT STUDIES - Annual

                 Year          No. of company  statements

              1972                       32
              1973                       29
              1974                       31
              1975                       37
              1976                       35

          2J  Development Planning and  Research Associates, Industry Survey
              results  from 135 companies for year of  1975.
                                       53

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                V.  PRICES AND PRICE DETERMINATION
The domestic price of leather is basically a function of the cost of raw
materials (hides), the demand in the U.S. consumer market and competition
among domestic and foreign leather tanners in the market.  Cost of raw
hides is determined by foreign and domestic competition for an inelastic
hide supply.  Demand for raw hides has virtually no influence on the supply
of hides for the U.S. tanning industry, as the hide supply is a function
of supply-demand factors affecting the cattle industry.  For the U.S.
tanners, their supply is primarily determined by the price they are willing
to pay.  Unquestionably, foreign hide demand has had an increasingly signifv
cant impact on the price U.S. tanners not only are willing to pay but also
have to pay to procure hides from which their commodity is produced and
priced.

Domestically, shoes have been the major leather good relative to demand
for leather but the shoe industry has recently experienced strong compe-
tition from foreign producers.  This has definitely hurt the leather in-
dustry causing declines in production, shifts to other leather good markets
and development of new markets.

In the following sections, characteristics of recent price and price
determination factors (supply and demand) will be analyzed more exten-
sively.  The initial subject will include a qualitative and quantita-
tive analysis of the supply, demand and prices of leather.  Then an
evaluation of leather product imports and trade restrictions affecting
leather will be presented, followed by an analysis of the raw hide market
and discussion of international trade and trade restrictions on raw hides.

              A.  Leather Prices, Demand, and Supply

Prices of leather and the demand and supply situation experienced by U.S.
leather tanners in recent years have been highly variable.  Both bullish
and bearish markets have existed, however, until the last couple years,
a bear market was the more dominant.  Although the last two or three years
have been favorable for the industry, most industry analysts are skeptical
or cautious due mainly to strong competition from foreign competition.

Leather Prices

The price of leather was at a record high in 1976.  The wholesale price
averaged over $1.00 per square foot, up about 40 percent from the pre-
vious year.  The price strength originated from the strong demand for
leather goods in 1976.  The U.S. shoe industry increased production 1\
percent over the year, leather garment sales increased and most
other  leather goods sectors experienced higher sales.

Associated with the increased leather prices were higher hide prices.
For example, heavy native steer hides average $.33 per pound or about
$.58 per square foot on a tanned leather basis.  This is the second
highest current dollar price  in recent years.  See Table 16.
                                  54

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                            Table 16.    Leather,  price per square  foot,  1955 to  1976  lV
tn
en
Current Dollars
Year

1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
Hide
Price 2J


21.7
21.7
19.2
20.0
33.6
24.0
26.1
26.6
19.6
18.0
24.3
30.4
20.5
20.6
25.2
22.4
25.4
52.1
59.0
45.3
41.1
57.8
Finished
Leather
Wholesale
Price 3_/
__/f/cn ft __

44.4
49.9
48.6
50.6
62.5
55.5
58.9
61.9
57.7
58.1
59.3
64.4
59.8
61.1
66.1
64.1
63.9
80.4
88.6
82.8
79.9
110.9
Hide to
Finished
Leather
Spread


22.7
28.2
29.4
30.6
28.9
31.5
32.8
35.3
38.1
40.1
35.0
34.0
39.3
40.5
35.9
41.7
38.5
28.3
29.6
37.5
38.8
53.1
Hide
Price


35.6
34.5
29.5
30.3
49.8
34.9
37.7
37.7
27.4
24.8
32.7
39.6
26.0
24.9
29.1
24.5
26.5
52.1
55.8
38.9
32.3
43.2
Real Dollars I/
Finished
Leather
Wholesale
Price
	 (t/cn ft -.

72.8
79.3
74.8
/D.5
92.6
80.8
85.0
87.7
80.6
79.9
79.8
83.9
75.7
74.0
76.2
70.1
66.6
80.4
83.7
71.1
62.8
82.9
Hide to
Finished
Leather
Spread


37.2
44.8
45.3
46.2
42.8
45.9
47.3
50.0
53.2
55.1
47.1
44.3
49.7
49.1
47.1
45.6
40.1
28.3
27.9
32.2
30.5
39.7
Hide to Finished
Leather Spread
as a Percent of
Finished Leather Price


51.1
56.5
60.5
60.4
46.2
58.0
55.7
57.0
66.0
69.1
59;1
52.8
65.7
66.2
68.8
65.0
60.3
35.2
33.4
45.3
48.5
47.9
      _!/  Sources:   Hide prices  -  USDA,  Livestock and Meat Statistics
                   Leather prices -  Department of Labor,  Bureau  of Labor Statistics,  Wholesale  Price  Index.
      21  Heavy Native  Steer Hides converted  to raw hide equivalent of one square  foot tanned  leather  (1.75
         pounds raw hide yields 1.0  square foot of tanned leather).
      3_/  Upper leather, cattle  and kid  sides,  smooth.
      4/  Prices adjusted by the GNP  Implicit Price Deflator,  Total  GNP,  1972  =  100.

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Historically, there has been a stable relationship between the price  of
leather and the price of hides.   The relationship was  essentially abso-
lute and was reflected by stable margins between the raw material and
finished product prices.  The margin stability was especially true for
the period from the late 1950's  to 1971.  After 1971,  market disruptions
made it difficult to maintain historical margins and classical relationships
had to be adjusted in order to retain sales although the margin adjustment
usually resulted in a loss.

The data in Table 16 include the current and real dollar values for
leather (wholesale), cattlehides (pound-price converted to equivalent of
one square foot of leather), and the equivalent square foot price spread
or margin.  The hide to finished price spread is graphed in Figure 4
which more clearly depicts the recent price spreads.  Over time the     ,,
current dollar price spread has  been increasing at about the rate of .64-'
cents per square foot per year.   Based on the 1955-76 average price spread
(x) of 35 cents per square foot, the average annual change or increase has
been about 1.8 percent per year.  The increase is necessary to offset ever
increasing production costs which consume much of the price spread.

Based on a real dollars analysis, the price spread on a trend basis has
been declining at about .59 £/ cents per square foot per year.  This
equates to average annual decrease of 1.4 percent per year'with the 22 year
average rea1 dollar margin (x) of 43.2 cents per square foot.  Thus,
although the margin has been increasing in current dollars, the increase
has not kept pace with the value of the dollar and the margin has de-
clined in real terms.

Increased competition and declining volume has kept the industry operators
from increasing production margins sufficiently to cover costs, and maintain
historical profit levels.  The industry has responded two ways: first, plants
are continually attempting and often succeeding to  increase production
efficiency, second, inefficient plants unable to cover increasing costs
with the small increase in market margins are eventually forced out of
business.  The existence of the latter situation is statistically por-
trayed by industry plant data.
V .64 cents per square foot per year is the coefficient of the trend
   line equation: 7=27.8 + .64 t where Y-j=margin in year-j,  and t=year-j,
   i-1, 2, ...,22 starting with 1955.

2/ .59 cents per square foot per year is the coefficient of the trend
   line equation: y=49.9 - .59t
   Where:   y = real dollar margin in year-j
            t = year-j, i=l, 2, ...,22 starting with 1955.
                                 56

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     60-
     50-
   CO
   s-
   03

O  1^
O  O
     40

o;
UJ
a.
   C£.
     20
      60
o:
o.
    01
    S-
    ns
      50
    o40
O  +->
•-i  C
DC  OJ
a.  i.

   3
      Of.
      30
      20
                                                              x  = 43.2
                                                              s  = 7.7
                                                              V*= 17.8%
                                                          V* = coefficient of
                                                                variability
          55     57     59     61     63    65    67     69    71    73    75     77

                                       Year 19
      Figure 4. The tanned  leather equivalent price spread between the price
                 of cattlehides  and wholesale price of leather, cents per
                 square  foot,  current and real dollars, 1955-1976.
                                          57

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Demand for Leather

The demand for leather is a derived demand resulting from consumer
interest in leather products.  However, to get a true perspective of
the demand for U.S. tanned leather, several other factors must be
taken into consideration in addition to the international demand for
leather.

First the domestic shoe industry, the primary customer for U.S. tanned
leather has slowly but steadily been losing its share of the domestic
market to international competition.  In 1965 only 12.3 percent of the
shoes purchased in the U.S.  were manufactured overseas, however, by  1976
this had increased to 47.6 percent.   Indications are that this trend
will continue over the foreseeable future.   During this time total  U.S.
demand for shoes fluctuated only slightly but in recent years since the
advent of high inflation the trend has been down.   Per capital consump-
tion reached a peak in 1968 with 4.07 pairs but since that time has
dropped to 3.43 pairs in 1975, but recovering significantly in 1976 to
3.94 pairs.

The resulting effect of the stable U.S.  demand and increasing imports
is the total pairs of shoes manufactured in the U.S. has declined
steadily, from 600 million pairs in 1965 to the 1975 level of 433
million pairc, a decline of 31 percent over the 10 year period (Table
17).  Production was up in 1976, 444 million pair, but this appeared
to be only an aberration as 8 months production data suggest that U.S.
shoe production will drop below 400 million pair in 1977.

A further decline in the demand for leather can be seen in Table 17
which shows the percent of U.S. manufactured shoes made with leather
soles.  This has been declining steadily over the past 30 years and by
1976 only 14.6 percent of the U.S. shoes were made with leather soles,
down from 25 percent in 1965.

During the 60's the substitution of synthetics for leather in the shoe
uppers made substantial inroads in the market.  In 1960 only 25 percent
of the U.S. shoes were made with synthetic uppers.  By 1976 this percentage
had increased to 48 percent.

In summary the demand for leather from U.S. tanners going into the
manufacture of shoes has declined from 78 percent of the total leather
produced in the U.S. in 1970 to only 56 percent in 1975 and 59 percent
in 1976 (Table 18).

Two and three years ago, demand for leather going into leather garments
was a bright  spot, accounting  for 190 million square feet of domestic
leather or 14.4 percent of the 1975 domestic productions.  Rapid in-
creases in imports from Korea  have cast a dim shadow over that market
                                  58

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       Table  17.  U.S. Production of Shoes 1965-1975,  (1,000 Pair).
en
to

1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
Total U.S.
Production
626,229
641 ,696
599,964
642,427
576,961
562,318
535,777
526,655
490,033
452,955
413,439
444,087
Percent of U.S.
Production
With Leather Soles
24.6
24.8
21.7
17.4
14.8
16.4
16.0
17.0
14.0
14.2
13.3
14.6

Total
87,632
96,135
129,137
175,292
202,040
241,560
268,569
296,665
315,514
294,457
319,430
404,455
Imports
Percent of Total
U.S. Consumption
12.3
13.2
17.7
21.4
25.9
30.0
33.4
36.0
39.2
39.1
42.4
47.7
Total
Shoes
713,861
737,831
729,101
817,719
779,001
803,878
804,346
823,320
805,547
747,412
732,919
848,542
Pairs
per
Capita
3.67
3.75
3.66
4.07
3.83
3.91
3.89
3.94
3.83
3.53
3.43
3.94
     Source:   Tanner's  Council  of  America,  "Membership  Bulletin  Leather  Industry Statistics".

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                 Table 18.  Leather markets profile 1976-actual and 1977 projected.

Products


Shoes (non rubber)
Leather Garments
Leather Work Stoves
(million do*, prs.)
Leather Handbags
Small Leather Goods
Leather Belts
Miscellaneous
(including luggage, uphol-
stery, saddlery, lace,
latigo, skirting, collar,
mechanical)
TOTAL

Shoes (non rubber)
Leather Garments
Leather Work Gloves
(million doz. prs. )
Leather Handbags
Small Leather Goods
Leather Belts
Miscellaneous (as above)
TOTAL
Total
Market
Supply
(Millions)

848
11

5.5
30.5
68
52
N.A.






790
9

6
31
78
48
N.A.

Domestic
Production
(Millions)

444
3.4

3.6
16.5
60
48
N.A.






375
3

3.8
15
69
43
N.A.

Imports
(Millions)
1976 Actual
404
7.6

1.9
14.0
8
4
N.A.





1977 Projected
415
6

2.2
16
9
5
N.A.

Imports
As % of
Total
Market


47.6
70

35
59
12
8
N.A.






52
67

37
52
12
10
N.A.

Leather Equivalent
of Domestic Prod.
Square ft.
(Millions)

770
140

107
90
60
55
85




1307

630
130

112
83
70
48
90
1163
Percent


58.9
10.7

8.2
6.9
4.6
4.2
6.5




100.0

54
11

10
7
6
4
8
100
Source:  Tanner Council  of America  "Membership  Bulletin Leather Industry Statistics".

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- some imported at extremely low prices - and in 1976, utilization for
leather garments declined to 140 million square feet in 1976, 11 per-
cent of the domestic production.  See Table 18.

Other areas where demand still  appears strong include: leather work gloves,
8.2 percent of leather produced; leather handbags, 6.9 percent; leather
belts, 4.2 percent; small leather goods, 4.6 percent; and miscellaneous,
6.5 percent.  Unfortunately, these segments represent less than 30
percent of the leather utilization in the United States.   See Table 18.

Supply of Leather

The tanning industry generally responds to the demand for leather, thus
production of U.S. leather is not necessarily related to  the supply of
U.S. hides.  Less than half of the hides produced in the  U.S. are consumed
by U.S. tanners for processing thus the U.S. tanners find themselves
competing with foreign tanneries for the available supply of U.S. hides.
On this basis, they will buy the necessary hides to fill  their expected
demand at a given price.  Whereas the total supply of hides available for
tanning has been increasing steadily in the U.S. the number of hides
going to the domestic tanners has been declining.

Shown in Table 19, are industry's annual production data  from 1955 to
1976.  The industries output has steadily declined throughout this period,
falling from 37.2 million equivalent hides in 1955 to a low of 20.0 million
in 1974.  On the average, production has declined 2 percent per year.  At
an output of 25 million equivalent hides, the 2 percent decline is equal
to 500,000 hides or about 20 million square feet of leather.  Such a
decline is equal to the annual  output of two medium sized chrome tanners.

  B.  Imports of Finished Leather Products into the United States

The United States is the world's largest importer of leather products
with Germany, the United Kingdom and Switzerland following in that order.
Importers know the United States is a big attractive market for foreign
leather products and the market has been growing at a rapid rate.
As a result, imports of leather goods into the U.S. have  been growing
at an accelerating rate.  This  has created what some industry experts
perceive as a very serious threat to the domestic tanning and leather
goods industries.

This trend has occurred in other developed countries.  In Germany, Sweden
and other countries, leather imports have reduced the leather tanning and
leather products industries to a fraction of their former size.  The exact
reasons for this shift are many and complex.  Basically,  the leather industry
is labor intensive and developing countries find they have certain advantages
in competing on a cost basis (however, we have not been able to quantify
these factors on any suitable basis).  Second it is an industry that does
not require a high level of technology such as the computer industry or
aircraft industry and can be adapted to developing countries.  Third, a
complicated series of trade restrictions have been built  up which prohibits
                              61

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Table 19.   Tanning industry production, cattlehide equivalents,
                 1955-1976
                          1,000 cattlehide            % change from
  Year                       equivalents              previous year
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
37,220
36,810
35,820
33,810
34,090
31,850
32,226
31,596
31,325
32,187
32,697
32,252
30,861
31,884
28,388
25,941
25,267
24,661
21,062
19,998
21,894
23,526
__
-1.1
-2.7
-5.6
+0.8
-6.6
+1.2
-2.0
-0.9 a
+2.8 c
+1.6 1
' -1.4 e
-4.3
+3.3
-10.9
-8.6
-2.6
-2.4
-14.6
-5.0
+9.5
+7.5
                                                                    average annual
                                                                    change from
                                                                    1955 to 1976
                                                                    equals -2.0%
                                  62

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the U.S. tanning and  leather  products  industries  from  competing  favorably
in foreign markets.   The  second  part of  this  section is  devoted  to  looking
at some of these aspects.   Fourth,  developing countries  such as  Korea,
Taiwan, and Brazil see  this industry as  one in which they  can compete on
an international basis  and  earn  a valuable source of badly needed foreign
exchange.  As a result  they tend to "push" the industry  in their countries.

Trends in Imported Leather Goods

Table 20 demonstrates the U.S. foreign  trade  in leather products.  The
value of imports have tripled from 1969 to 1976 increasing from $631
million to over $2.17 billion in 1976.   Exports during this period  increased
rapidly but in 1976 amounted to only $111 million or only 5.1 percent of
imports.

Footwear is the major product imported  accounting for two-thirds of total
imports in 1976.  It makes up approximately the same proportion of  total
imports today as it did 5 years ago.  Leather wearing apparel has made
rapid increases since 1972 and is the second  most important oroduct line.
Again in 1976, leather apparel imports made rapid increases.   Handbags
and luggage make up the next most important categories with imports of
$185 million and $161 million respectively in 1976.

The following observations are obtained from viewing import statistics.
Latin American countries have good access to  the United States  market;
Mexico, Columbia and Brazil  regularly export certain types of leather goods.
Lebanon, Morocco, Yugoslavia and Hong Kong are the only developing  countries
outside Latin America which regularly export certain types of leather goods
to the United States.  Some developing  countries have begun to  emerge as
suppliers in recent years.  For example,. Israel, the Republic of Korea and
China (Taiwan) have become important exporters of leather products  to the
U.S.

Trade Restrictions

Foreign sources have free access to U.S.  raw hides and skins.  At the same
time, U.S.  tanners are denied equal  access to foreign leather markets.
This is one of the primary concerns of  the U.S. leather tanning industry.

Representatives of the U.S. leather industry  feel that current and past
trade legislation and duties have not been effective in curtailing U.S.
imports of leather and leather products.   Therefore, they  are not in favor
of any further cuts in U.S. duties  on competitive imports.

The following section is an overview of some  of the tariffs and trade
legislation which has and/or could  affect the industry.  The following
discussion is largely taken from a  report, Leather and Leather Products,
which was published by the United Nations in  1971.
                                   63

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Table  20.  United States Foreign Trade in Leather Products ($1,000)

Imports
Year
1969
1970
1971
1972
1973
1974
1975
1976
Footwear—'
435,884
559,347
678,352
832,652
976,106
982,892
1,135,348
1,452,358
Wearing
apparel
19,674
38,233
59,251
91,773
109,728
123,066
154,334
236,587
Handbags
& purses
58,420
62,974
67,606
83,623
108,211
106,853
124,776
185,000
Luggage &
flat goods
38,393
41,366
49,758
76,795
100,231
95,890
89,486
160,754
Other
products
78,643
87,282
74,188
83,561
94,380
106,723
81,963
140,086
Total
imports
631,014
789,202
929,155
1,168,404
1,388,656
1,415,424
1,585,907
2,174,785
Total
Exports
33,984
35,732
36,987
43,756
55,037
79,754
88,852
110,904
I/  Other than rubber
Source:  Tanners Council of America
                                      64

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Tariff Structures

Tariffs have a tendency to increase as the degree of processing or the
manufacturing content of the article increases.   The leather industry is
an example of this.  In all countries most raw hides and skins enter duty
free.  Leather tends to carry a tariff of about 5 to 10 percent, while
leather footwear and other finished articles tend to carry tariffs of
between 10 and 25 percent.  Japan and Finland are exceptions to this ten-
dency of tariffs to escalate as manufacturing content increases.  Japan
has elaborate sets of restrictions on leather and leather goods imports.
It is the only country which imposes restrictions on imports of leather
itself.

Effective Rates  of Tariffs

A tariff imposed on the principal product of some industry affords that
industry increased protection.  In order to measure the effective degree
of protection consideration must be given to all of the relevant tariffs
and not merely those on the principal product or products of  the  industry.

An Effective Tariff Rate is defined as the percentage increase in value
added per unit of output in a given industry which is made possible by
the tariff structure.  The effective tariff rate is a measure of the
excess remuneration of domestic factors of production, obtainable because
of the tariffs, as a percentage of what value added would be in a free-
trade situation.

A tariff on the outputs of an industry and none of the inputs results in
the effective tariff rate being higher than the nominal rate (price)
(see Table  21 ).   In the Leather Industry, since the tariff rate escalates
with increasing levels of production, the effective rate of protection is
even greater than  the nominal tariff applied to leather.  The effective
rate of protection for footwear or other leather product industries tends
to be greater than the nominal tariffs on leather products.

The effective rate of protection is dependent on three factors:  (1) the
cost structure of  the industry; (2) the nominal  tariff on output; and
(3) the difference between this rate and tariffs on inputs.  Owing to
the sensitivity of effective rates to differences between tariffs on out-
puts and tariffs on inputs, it does not follow that because the level of
nominal tariffs is escalating effective rates must be escalating.  On
the contrary, the  effective rates of protection may easily be just as high
at the earlier stages of production as at the later stages of production.
This is particularly true if value added is relatively small at the earlier
stages.

Effect of Current  Legislation

Current and  past trade legislation  and duties have  not  been effective  in
curtailing U.S.  imports of  leather  and leather  products.  Therefore, many
industry  leaders  are  lobbying  for more effective tariff  rates  and they  are
definitely not  in  favor of  any further cuts  in  U.S. duties on  competitive
imports.
                                     65

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      Table  21.   Effective Rates  of Protection  for Leather  and  Footwear  Industries.
                   (Illustrative  calculation  using  United  States  data,  post-Kennedy  Round tariff  rates)
en
Leather
Input Structure
Hides and skins
Other inputs
Value added
TOTAL

Leather
Hides and skins
Tanning Industry
Without
Tariffs
(hypothetical )
37
29.5
27.8
94.3

Tanning Industry
(percent)

Other inputs (chemicals, detergents,
Leather


Effective rate on
Effective rate on

With .
Tariffs
(actual )
37
31
32
100
Tariff Rates

0
etc.) 5
6
tannii.g:
leather footwei

Leather Footwear Industry
Without
Tariffs
Input -Structure (hypothetical)
Leather
Other i
18.9
nputs 30.8
Value added 37.3
TOTAL
Used

Leather
Other i
Leather
32-27
27.8
ir- 47'37
11 ' 37.3
87.0

Leather Footwear Industry
(percent)

nputs (rubber, plastics, etc.)
footwear
g
•' 13 PCI Utill l>
* — OC nov^on-fr*
£O pel LGII L

With
Tariffs
(actual)
20
33
47
100


6
7
13

      Source:   Leather and  Leather  Products,  United  Nations,  1971.

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A number of trade associations, particularly the American Footwear Industries
Association, have petitioned the U.S. International  Trade Commission to conduct
investigations concerning serious injury or threats  of serious injury to the
industry.  The Commission's findings on the basis of its investigation was
that "footwear is being imported in such increased quantities as to be a
substantial cause of serious injury to the domestic  industry or certain
industries producing articles like or directly competitive with imported
articles."  The Commission has not made any decision pending the completion
of its investigation.

In the past years there have been attempts to pass legislation which would
enhance the international trade position of the industry.  The Kennedy Round
is one.  With only one exception, the Kennedy Round  decreased the effective
rates of protection through modest reductions in tariffs.  Hides and skins
already entered free of duty so that no reductions were called for.  Rates
for pre-tanned leather were reduced very little.  In the case of finished
leather, the United States halved its rates.

The Generalized System of Preferences (GSP) is another trade legislation
which was intended to establish a system of generalized preferences in
favor of developing countries.  The impact of the Generalized System of
Preferences is to permit manufactured and semi-manufactured products by
developing countries to enter duty-free.  The overall objective is to en-
courage the industrialization of developing countries through increased
export earnings.

The GSP did not have any noticeable affect on hides  and skins exports
because they were allowed to enter duty-free before this 1970 agreement.
In the semi-manufactured group of products, many countries have exceptions
in terms of the products covered by GSP.  For example, the U.S. does not
give preferential treatment to all types of footwear.  The overall affect
of .the GSP is also reduced due to the fact that many countries set upper
limits on the value of items that will be given preference.  In general,
the effect of the GSP has lessened in the case of leather and leather
products because so many developed market economies  have various exceptions
and restrictions imposed on items which are covered by the agreement.

In 1975 the Trade Act recommends that the Administration arrange for
international agreements which would establish procedures for the impor-
tation of certain articles, including footwear, into the United States.
In addition, the 1974 Trade Act prohibits extending the Generalized System
of Preferences.
                                       67

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                        C.  The Raw Hide Market

Cattle hides are the primary raw material used in the leather tanning industry
and are a by-product of the meat industry.  For example, the value of a raw
cattlehide traditionally represents only 3 to 6 percent of the value of the
live animal.  As a result, the supply of hides is highly inelastic, i.e.
neither price nor demand for hides has substantial influence on the total
hide supply.

Price and demand will alter the destination of the raw hide supply.  Recently,
more of the supplies have entered the world market and international trade
has become an even greater concern relative to raw hide movement.   For example,
in 1976, for the first time, over half of the cattlehides were exported to
foreign tanneries and their effect on domestic prices has been substantial.
It is vital that one look at the broad international setting to understand
the price of raw materials as well as leather and leather goods prices.

Supply of Hides

The supply of cattlehides in the U.S. has been steadily increasing over the
past two decades as shown in Table 22.   In 1955, 26 million cattle were
slaughtered commercially in the U.S.  including 19 million slaughtered as
Federal Inspected Slaughter (F.I.S.), and an additional 7 million  were
slaughtered in other commercial establishments^/.  This number remained
constant to 1960 when again 25.2 million head were slaughtered.  During
the 60's the number.grew rapidly as the cattle feeding industry developed
and greatly increased the total U.S.  capacity over the previously  grass
fattened production.   By 1970 the number increased to 35.2 million where
it stabilized for the next few years  then slaughter increased to 40.9
and 42.6 million head in 1975 and 1976 respectively as the large buildup
of cattle numbers was reduced.   Since 1960, the rate of cattle slaughter
increased in the U.S. at approximately 1 million head per year.  Approxi-
mately 50 percent of all cattle slaughtered were classified as heavy steers.
Only 2.0 percent were bulls and stags, with the remaining 48 percent
classified as cows and heifers.

Total cattle numbers in the U.S. are estimated at 122.9 million head.
Based on this number the U.S. experienced a hide take-off rate of 35 percent
in 1976 (a recent low was hit in 1973 with a take-off rate of 27.7 percent).

The livestock industry is firmly established in the U.S. and in spite of
recognized ups and downs is committed to long term growth assuring the
tanning industry an increasing supply of cattlehides in the future.

Suppliers of other types of leather making raw material do not show the
same trend as cattlehides.  Prior to 1974, calfskin supplies had been
shrinking drastically in the U.S. and, although making recent gains, are
not expected to be a dominant factor in the market in the future.   Calfskin
production in 1976 was estimated at 4.5 million skins which represented
a 40 percent rise above 1974 production of about 3.2 million skins.  Sheep
and lamb skins, the only other major source of hides and skins in the U.S.,
have been declining steadily in the U.S. over the past two decades.  Although
the numbers are responsive to price developments in meat and wool, the long
 \J  Federal  Inspected  Slaughter means  that the  animal  is  slaughtered  and
     processed in a slaughterhouse and  inspected by  federal  meat inspectors.
     This allows  the meat to  be identified as  such and  in  turn  allows  the
     meat to  be sold interstate.

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               Table*22.   Annual  cattle  slaughter in the United States, 1955-1975, (.1,1000 head)
IO
Breakdown of federally


1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
Cows &
hei fers
9,330
9,460
9., 031
7,509
7,538
8,567
8,554
8,670
8,964
10,452
12,712
13,055
12,710
13,771
14,284
13,677
13,856
13,932
13,293
14,755
19,838
20,815
%
Total
48.9
46.9
46.4
42.6
43.2
44.2
42.8
42.6
41.4
41.6
47.8
47.8
45.8
46.5
46.8
44.4
44.1
43.2
43.6
44.3
53.8
53.4

Steers
9,299
10,311
10,018
9,840
9,681
10,557
11,164
11 .447
12,496
14,395
13,488
13,846
14,676
15,361
15,754
16,608
17,003
17,737
16,591
17,824
16,071
17,270
%
Total
48.8
51.1
51.5
55.8
55.4
54.4
55.!)
56.3
57.7
57.3
50.7
50.7
52.8
51.9
51.6
53.9
54J
55.0
54.0
53.5
43.5
44.3
inspected
Bulls &
stags
427
415
404
293
241
272
250
222
202
286
413
418
384
460
499
508
560
581
611
740
995
907
slaughter
%
Total
2.3
2.0
2.1
1.6
1.4
1.4
1.3
1.1
0.9
1.1
1.5
1.5
1.4
1.6
1.6
1.7
1.8
1.8
2.0
2.2
2.7
2,3

Total
F.I.S,
19,056
20,186
19,453
17,642
17,460
19,396
19,968
20,339
21,662
25,133
26,613
27,319
27,780
29,592
30,537
30,793
31,419
32,250
30,521
33,319
36,904
38,992
Total
commercial
slaughter
25,723
26,862
26,232
23,555
22,931
25,224
25,635
26,083
27,231
30,818
32,347
33,725
33.869
35,026
35,237
35,025
35,585
35,774
33,687
36,811
40,900
42,644
     Source:  Tanners Council of America,  Inc.

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term prospect of sheepskins from domestic sources is declining.   Sheepskin
production, which was estimated at 11.5 million in 1976 dropped  approxi-
mately 2 percent from the 1975 level of 11.7 million skins.

Total movement of cattlehides to U.S. tanners has been decreasing over the
past 10 years as U.S. tanners and the U.S. shoe industry have been confronted
with stiff international competition and restrictive trade legislation.  Total
wettings of domestic tanneries decreased from 23.5 million hides or 66.8 per-
cent of the U.S. total cattlehide production in 1966 to 17.5 million hides
or 46.5 percent in 1974.  Total wetting increased in 1975 and 1976 to 19.1
million and 20.4 million respectively.  These levels represented 46 and 47
percent of the total U.S. cattlehide production in those two years.  See
Table 23.

World Supply- of H.ides and Skins.

Cattle numbers in the U.S. and throughout the world were on  an upward trend
prior to 1976, after which time drought in many countries and unfavorable
prices in key countries have caused cattleherd reductions.  The  Foreign
Agriculture Service of the USDA estimated cattle numbers in  1974 at 707
million with an estimated increase to 724 million in 1975 or approximately
a 2 percent increase.  Production for 1976 was down, however, by about 2
million head and is expected to decline further in 1977, dropping to 715
million head.  This is still well above historic levels as the average
1968-1972 production was 635 million head per year.  See Table 24.

For countries that data are reported, the U.S. is the largest producer accounting
for about 18 percent of the world production.  The USSR is second with about
15 percent.  Other countries have more cattle, specifically  India, but as
they are not slaughtered in the countries, no major hide production occurs
as hides are only removed from some fallen animals.

A more meaningful number is the total hides produced by country shown in
Table 25.  As estimated by the Foreign Agriculture Service,  total hide
production in the 1966-1970 period averaged 176 million hides per year.
This decreased slightly over the next few years as slaughter rates de-
clined but increased sharply in 1974 and 1975 to 182.7 and 198.5 million
hides respectively.

The U.S. is clearly the leader in hide production with a reported 49.9 million
estimated take off in 1975.  As this estimate by the FAS includes an estimate
for death losses, we would argue that this number is probably overstated by
6-8 million hides.  This is due to the fact that hides from animals which die
in the field are often not useable for tanning.  When such an adjustment is
made, the FAS estimate of hide production is in line with the estimate prepared
by the Tanners' Council (Table 22).  The USSR is next in  importance with 37.0
million hides.  Argentina and Brazil produced an estimated 13.2 and 11.3 million
hides in 1975.  It is interesting to note that although Brazil has an estimated
91 million head of cattle compared to Argentina's 58 million, Argentina produces
a higher number of hides.  This is due to the low quality and poor slaughter
rate in many Brazilian herds.

                                      70

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           Table  23.  'Movement into sites of cattlehides, expressed in number  (1,000  hides)
                            and  as  a percent of total estimated slaughter I/
Year
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
Estimated
total
slaughter
35,260
35,381
36,076
36,118
35,740
36,280
36,480
34,700
37,700
41 ,800
43,582
Exports and
Re-Exports
number
14,205
11,866
12,853
14,790
15,229
15,969
17,584
16,871
18,444
21,287
25,280
percent
40.3
33.5
35.6
40.9
42.6
44.0
48.2
48.6
48.9
50.9
58.0
Imports
number
221
232
494
277
385
275
292
694
520
958
962
percent
0.6
0.6
1.4
0.7
1.1
0.7
0.8
2.0
1.4
2.3
2.2
Net Export
number
13,984
11,634
12,359
14,513
14,844
15,694
17,292
16,177
17,924
20,329
24,318
percent
39.6
32.9
34.2
40.2
41.5
43.2
47.4
46.6
47.5
48.6
55.8
Total Movement
to Tanners
number
23,572
23,607
23,617
21,096
20,199
20,189
19,218
17,733
17,536
19,067
20,397
percent
66.8 .
66.7
65.5
58.4
56.5
55.6
52.7
51.1
46.5
45.6
46.8
\J  It should be noted net exports plus  total  movements  to  Tanners  do  not  necessarily equal total estimated
    slaughter.  This is accounted for by the fact that not  all  slaughtered animals produce useable hides as
    well as the fact that some hides  may move to tanners before they are exported.

Source:   Tanner Council of America "Membership Bulletin  Leather Industry Statistics", 1976.

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Table  24.
                           CATTLE A1TO lUTTALbt  UMBERS 11 SPtCIflCO COUNTRIES    - 4VEK481 1966-72,  4MNJ4L  1473-7'
                                                              IN U117S Of  1.000  Mt»0

""""• *"° e'u'949
1 >364
,406
• 723
1 .839
78.974
.624
.760

.072
.909

94,942


5,482
1.931
12.309
5.697
5,411
37,377
106,246


11,911
235
7,265
3,650
1,545
5.107
14.259
32,341

4.415
40,254
706.604

1475
1 ,006
• 616
,900
,074
,031
,669
2 ,700
,506
,34*
131,626

166,842


3,406
23.032
7. 543
4,260
11,362
9,404
207,747
3.103
3,040
>4,327
14,430
6,500
4,719
14,640
79,22?
2,561
1,704
947
1.100
1.679

95,065


5,585
2,016
12.815
5,963
5.172
36,461
109,122


12,333
242
7,200
3,644
1,156
4,769
14,410
32,423
31,793
4,445
42,438
724.4(1

1474
13,694
,894
.950
.100
.146
.750

.600
.361
127.976

163.675

95.000
3.336
23.222
2.725
4,260
10.701
9.592
207,686
.011
.060
2 .841
1 .493
.966
.606
13.915
77,421
2.500
1,702
9U1
1.000
1.676

93.113
1,725
4,555
5.532
1.904
11.762
4.126
5.755
31,359
111.034


12.774
249
7,250
3,723
1.442
4,462
14,602
32,451
33.434
9,749
43,203
722.495

1977'
13,165
1.970
2,100
1,162
2,270

2,720
1,375

178,076


3.100
23.659
2.664
4,300
10,750
9,764
209,007
3,016
3.060
23.510
14,520
6.060
4.523
13.300
76,669
2.469
1,661

1,000
1.670

92,571


5,470
1.666
12.045
4.349
5,630
38.026
110,300


13,146
244
7,300
3,875
1,401
4.450
15,000
32,745

9.572
41.5T2
T15.lt 96
       IS FOGSIEL!.
I/ PSEUJOH1HT.
J_l MTi OTCIODED IS THE 1TEE1CZ TOE THESE
                                                 1EE (OT CCHF1BABLE TO SUBiBJUiJT TE1HS EHW7I BEC1DSZ 07 1 BEE1I
FOKEIGH iGRICULTOHAL SERVICE.  PBEPAXCD OB ESTHUTiS OH THE BASIS 07 077ICIAL STATISTICS OT funcICB GOTZBSHEUT5 . vraut 70EEIGV
EEKfRTG 07 U.S. AGRICULTURAL ATTACHES AHD 70REIGH SERVICE 077ICEES, HESOT.TS 0? OFFICE KESEABCB. AKD RELATED IHFORMATIOK.
                                                                                                                 THE OmCIU, SERTET,.

                                                                                                                               KATER11LC .
                                                                      72

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             Average 1966-70,  Annual 1971-75.








10*1- -mc'i






Ul






(41U I*- 1
»[«-••,!, DT1.. P.O. 1 •
144 ,115 0
en i7» •
t7t ,101 T 1
TJ7 .110 ttl
t»J ,tSJ tit
• IS TSt Til
• IS (II ITS
Sll 513 4»s
45? Ill lie
377 40: ISt


3?.«3» 33,146 It.?6S

l.ttl 1,6*1 1.101
I,I7C I,IS4 1.111
IC.Stt 10, IX t,»33
.1.4,0 .1.111 11. .Cl
17,»74 14,700 14. Sll
1,444 l.lll I.1JS
1.444 I, lit t.tIS
41 4S 17
««t 411 ttl
^61 1.15] 1.135
»41 174 I|t

4, til S.IOI t,014
1.TT1 ».0tl T.3I.
*.!•• I.»|4 t.tOI
1.511 «.t04 It. til
176,474 174. llf |I4. t4t
It73

111
lit

ll.lt*

4t.ltl

11.140
IllIT
141
tto
l.llt
IlllO
Ft, 354
I.Otl
in
101
• 40
tI3
711
Til
471
1S5


>0.07>

1.66*.
403
1.4.4
• ,Tt3
It. 141
14.1J8
r.toi
l.tOl
475
61 1
141
Ttl
littl
t.ior
t.l.T
l.tj.
II. US
1TI.MO
l»l.

lit
It'

4,t66
/•T
41. TIT

SJ.744


JJJ
isr
•••

l.ltt
II. TIT
1S1
us
• 74
44»
• 77
too
404
• IT
110
404
its
7.4

IS. OS?

l.44t
423
I.1S&
|**»SO
.J.T.I
IS »»C
I. IS]
1.153
J:
• 45
1.11-
115
TSt
1,165
t.IK
4,741
1.117
*.«S<
HI. 447
I»7V
4.t4t
IK
lot
Itl
}l»4
t.ltl
1/7
III
4t.tTI

tl.ltt

II. It!
ISO
174
Til
i.tst
I..M
Jl.tt5
I.ISt
1,111
4,001
1 . 7 1 0
.,111
I.OIC
4. t>C
I7.ISI
• 44
TIS
553
>t4
441


14.111

I.IC'
.SI
I.IS.
11. (>:
4S..t7
17, etc
1.155
i. its
.
1.7'
41 .
TTI
l.*0t
7.0»
• .147
>.44T '
II. Ht
l*t.»4f
  ~\i :':r-unr; »•: tri vrt r."
  ;/ sa.i*x; v'*••_' »
  V ir^LVCi 3V TiLCD.
Source:  Foreign Agricultural  Service.   Prepared or estimated  on the
         basis of official  statistics of foreign governments,  other
         foreign source materials,  reports of U.S. Agricultural  attaches
         and foreign  service officiers, results of office  research and
         related information.   September 1976.

                               73   '

-------
Australian hide production has fluctuated widely from a low of 5.8 million
during the 1966-70 period to a high of 9.2 million in 1975.  This is due
to the volatile cattle market in Australia since they have a great dependence
on the international beef market which also has fluctuated in recent years.
A very high herd build up in 1973-1974 has resulted in sharp herd reductions
and high slaughter rates in 1975.

The Demand for Raw Hides

The U.S. tanners must compete directly with foreign buyers for the supply
of hides made available as a by-product of the livestock slaughter industry.
In this section we will deal primarily with the international demand for
hides.  In earlier sections we looked at the demand placed on the U.S. tanners
for leather and leather products which, in turn, translates directly into
the U.S. demand for raw hides.

Exports of raw hides have increased steadily over the past two decades.
The total international supply has been restricted by trade practices and
accordingly the U.S. Leather Tanning Industry has been gradually losing
Its market share to foreign shoe and leather-goods manufacturers.  In
1966, 40 percent of the cattlehides produced in the U.S. were exported and
by 1976 net exports had increased to 56 percent.  This amounted to a total
of 24.3 million hides being exported in 1976.  United States tanners pur-
chased 1.0 million hides from foreign  sources (primarily Canada and Mexico).

The rate at which the United States exports of raw hides has increased is
shown in Table  26.  Nearly one-third of U.S. hides are exported to the
Japanese market with about 7.8 million hides exported in 1975.  Mexico
and Korea are next in importance with about 2.5 million hides each.  It
is significant to note the rapid increase in exports to Korea as they
jumped from 411 thousand hides in 1972 to the 2.5 million reported for
1975.  Other countries with rapid increases in U.S. hide purchases are
Poland and Taiwan.  The majority of the remainder of the increase in inter-
national demand for U.S. hides is reflected in the hides shipped to other
countries which doubled from 1972 to 1975 with an estimated  1.2 million
hides exported in 1975.

Argentina has traditionally been a large exporter of hides with an .annual
average of 8 to 8.5 million hides exported from 1966 to 1969.  Argentine
exports declined slightly in 1970 then sharply in 1971 and amounted to only
1.3 million in 1972.  This has been caused by their internal production
problems and also an attempt to completely internalize their hide industry
and eventually only export finished leather products.  Brazil also internalized
the hide tanning industry and banned exports of raw hides  further reducing
world supply by two million hides.  Recently Brazil has become an importer
of raw  hides and is now competing for raw hides on an international basis.

In summary, we are  basically  in a demand pull situation for  raw hides.
Foreign demand for  our raw  hides, which now takes over 50  percent of total
U.S.  produced  cattlehides, will continue and possibly expand.  Only the
U.S., Canada and Australia  remain as major raw hide exporters.  Nearly all
                                      74

-------
 Table 26.   Exports of Cattlehides  from the U.S.  and Other Major
            Exporting Countries to  Countries of Destination,  1972-1975.
Country of
Destination Unit
United States:
Japan 1 ,000 pcs.
Mexico "
Korea, Republic of "
Romania "
Spain "
Canada "
Czechoslovakia "
Poland
China, Republic of (Taiwan) "
Italy
USSR
France "
Germany, West "
Hong Kong "
Hungary . "
Netherlands "
Yugoslavia "
Israel "
Turkey "
United Kingdom "
Chile
Other countries "
TOTAL
Australia
Total Cattlehide equiv. "
1972

7,769
1,806
411
1,200
854
1,121
857
568
226
263
518
771
729
68
228
449
459
132
4?
. 245
261
673
19,650

4,343
1973

7,596
2,036
908
1,006
620
905
821
766
332
605
48
591
656
98
201
160
273
140
66
199
273
452
18,752

3,878
1974

7,199
2,534
1,535
1,781
643
907
676
666
486
434
450
339
641
161
532
159
226
134
79
50
134
829
20,595

4,082
1975^

7,760
2,588
2,543
1,226
1 ,009
958
877
866
864
773
660
510
440
381
262
239
160
152
102
61
24
1,217
23,672

5,616
Canada
  Total Cattlehide equiv.

Argentina
2,914   2,729   2,650   3,853

1,344     	
Source:  USDA, Foreign Agriculture Service,  Foreign Agricultural  Circular,
         Livestock and Meat, September,  1976.

         Argentina:  Tanners Council  of  America.
                                75

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other historical exporters such as India, the Argentine and Brazil have
internalized their leather tanning industries and no longer allow the
export of raw hides.  International demand for hides has broadened with
Japan taking the lead.  Korea and Taiwan have sharply increased imports
and Communist Bloc countries such as Poland, Yugoslavia, Rumania and
Czechoslovakia have more than doubled their imports of raw hides since 1965.
As a result, we see the U.S. tanners facing continued international competition
for our raw hides.

Trade Restrictions in Raw Hide Supply

Systematic restriction on exports of hides and skins appears to be the
trend in developing countries.  Their basic policy is to restrict exports
of raw materials (hides and skins) while simultaneously encouraging exports,
and restricting imports, of the manufactured goods (leather and leather
products).  This is done by levying taxes on exports of raw hides and skins,
imposing quotas on imports; and granting incentives for exports of manu-
factured goods.

When raw hides and skins are converted into leather their value increases by
more than two and a half times.  Benefits, particularly for developing countries
are derived by restricting their exports of raw hides and skins and developing
their own domestic tanneries.  Developing countries gain advantages by restric-
ting their export of raw hides and increasing their export of semi-tanned
leather due to the preferences given by other countries to pre-tanned leather.
These advantages are the results of (1) developing countries not having the
technological sophistication to develop high quality finished products; (2)
primary stages of leather processing being labor intensive, and developed
countries-finding it difficult to attract and retain sufficient quantities
of labor, and (3) developing countries being unable to keep abreast of fashion
changes as readily as developed countries.

In a review of the effects of some of its more recent tariff legislation,
such as The Kennedy Round, the U.S. Government has indicated its findings
show little effect has been made on changing existing import-export patterns.
An overview of the estimated effects of the Kennedy Round on tariff barriers
dealing with raw hides and skins follows.
                                     •
In 1968, one-third of the approximate $452.6 million raw hides and skins
imports was supplied by developing countries to the four major import
markets:  EEC, the United States, Japan, and the United Kingdom.  Latin
American countries, i.e., Argentina, Brazil, and Uruguay are the main
developing country suppliers.  Prior to the Kennedy Round, entrance into
major market areas was duty-free, with the exception of the United Kingdom
and the United States.  The Kennedy Round negotiations abolished the tariffs
in these market areas which resulted in duty-free access to all four major
markets.

In 1968, almost one-half of the sheep and lambskin imports were supplied
by developing countries.  The bigger importers were the EEC, the United
Kingdom, and the United States, the latter which is also an important
supplier.  The Kennedy Round improved access to the four major markets
and "effective protection" of processing was reduced.   Japan imposed
relatively high duties and quantitative restrictions on some items.


                                   76

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Also in 1968, eighty-seven percent of all  goat and kid skin was  supplied
by developing countries.  The major importers were the EEC, United Kingdom,
United States, and Japan.  The Kennedy Round resulted in improved market
access and reduced the "effective protection" of major importers.   Nominal
duties still apply to some varieties of goat and kid leather.   The resultant
effect of these policies is that now only the United States, Canada,
Australia and New Zealand remain as open markets for the purchase of  raw
goat and kid skins.
                                      77

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                        VI.  MODEL PLANTS
The Leather Tanning and Finishing Industry is comprised of nearly 250
establishments which utilize variations of basic processes to produce
differentiated types of leather.   The Industry consists of establishments
primarily engaged in tanning, currying and finishing hides and skins into
leather.  As this chapter is concerned with the development of economic
plants representative of tanneries and leather finishers which could be
effected by the imposition of hazardous waste management regulations, an
attempt will be made to describe models which together will typify most
tannery operations in the United States.

               A.  Types and Sizes of Model Plants

Tanneries vary with respect to their operating characteristics such that
several models were required to be developed.  However, these models do
not totally represent all tanneries.  Instead it is believed that the
models developed represent various categories of tanneries with each
respective tannery in that group having several characteristics closely
associated with the models.

The general categories of tanneries utilized in this analysis are defined
below:

    1.  Cattlehide-chrome--a tannery that primarily processes raw or
        cured cattle or cattle-like hides into finished leather using
        chrome tanning.  Hide hair can either be saved or chemically
        dissolved.

    2.  Cattle-nonchrome (primarily vegetable)--a tannery that primarily
        processes raw or cured cattle or cattle-like hides into finished
        leather using less than 20 percent (by hide weight) chrome tanning;
        includes vegetable, alum, syntans, oils, and other methods and
        their combinations.

    3.  Cattle-to-blue--a tannery that primarily processes raw or cured
        cattle or cattle-like hides through the blue tanned state only,
        with no retaining or finishing operations, and uses chrome tanning.

    4.  Cattle splits (retan)—a tannery that primarily processes splits
        or previously tanned hides and/or skins into finished leather,
        the major wet process consisting of trimming, additional splitting,
        retanning, coloring, and fatliquoring.

    5.  Sheepskin tannery—a tannery that primarily processes sheepskins,
        with the hair previously removed, into finished leather using
        either chrome or nonchrome tanning methods, primarily includes
        pickled sheepskins.  A few plants will also tan pigskins or
        pickled cattlehides  (hair removed) and such plants will occas-
        sionally be called no-beamhouse tanneries.


                                   78

-------
    7.   Shearlings—a tannery that primarily processes  raw  or  cured  sheep
        or sheep-like skins,  with the wool  or hair retained on the hide,
        into finished leather using chrome  or nonchrome tanning;  or,  a
        wool pullery—a plant that processes hair-on raw or cured sheep
        or sheep-like skins by first removing the wool  and  then pickling
        the skin for  use by a sheepskin tannery (Category 6).

    8.   Leather finishers—an establishment that receives unfinished
        leather to  which it applies a finish and may also buff to re-
        move imperfections  in the leather;  does not perform any other
        tanning functions;  normally functions on a contract basis in
        performing  a  service  for a customer.

For each of the above categories at least one representative model was
considered.  Where  there were several corresponding tanneries  associated
with a category, various representative sizes of models were developed
for that specific category.  The models and their corresponding sizes  are
depicted in Table 27.

Table 28 depicts the  various operational characteristics of the model
plants.  These characteristics were determined from the industry  survey
as well as discussions with industry members.  As is shown, operations
involving cattlehides predominately operate 250 days per year  utilizing
approximately 85 percent of their capacity.  Sheep operations  commonly
operate 240 days per  year with sheepskin operations utilizing  75  percent
of their capacity while shearling operations utilize 90 percent during
1976.  Finishers are  generally on a 250 day per year operation schedule
using 76 percent of their capacity and measure output on a  square foot basis.

To compute the annual production of the other models in terms  of  square
footage the following standards were used:

    Cattlehides yield 40 square feet per hide; cattle splits yield  8
    square feet per split; and sheepskins yield 6.67 square feet per
    skin or pelt.

At this  time  it does  not  appear that vegetable tanners will be impacted.
This conclusion is based  on  information from a recent  EPA  study  on  solid
waste  practices in the leather industry.   The study determined that  a
typical  vegetable  tanner  will  produce no potentially hazardous waste.!'
Model  plants  were  included,  however, to facilitate future  analysis  if
they are  eventually  required to conform to similar regulations.
 !_/  SCS  Engineers,  Inc.   Assessment of Industrial  Hazardous  Waste  Practices  —
    Leather Tanning and Finishing Industry, EPA report under Contract No.
    68-01-3261,  Report No.  PB-261-018, November 1976,  p.  83-84.


                                  79

-------
                      Table 27.   The Leather  Tanning  Industry,  representative model  plants
                                         and respective  plant capacities
CO
o
Model

Cattlehide
pulp
Cattlehide
save
Cattlehide
Cattlehide
Cattle spl
Sheepskins
Shearlings
Leather Fi

, chrome,
, chrome,
, vegetable
to blue only
its


nishers
Corresponding
Category

1
2
3
4
5
6
7
8

Units X-Small
(Units/Day)
Cattlehides 100
Cattlehides 100
Cattlehides
Cattlehides
Splits
Sheepskins —
Pelts
sq. ft.

Small

400
400
100
—
—
1,200
900
—
Size
Medium

900
900
625
—
4,250
2,400
—
14,000


Large

1
1
1
3

5
3
40

,500
,500
,500
,000
—
,800
,000
,000

X-Large

3,000
3,000
—
—
—
—
—
—

-------
                           Table  28.  The Leather Tanning Industry, representative modf. plants'
                                              operational characteristics
00
Model /Size

Cattle-Chrome
X-Small
Small
Medium
Large
X-Large
Cattle Vegetable
Small
Medium
Large
Cattle to blue
Large
Cattle Splits
Medium
Sheepskins
Small
Medium
Large
Shearlings
Small
Large
Finishers
Medium
Large
Category Capacity
(Units/Day)
1 & 2
100
400
900
1,500
3,000
3
100
625
1,500
4
3,000
5
4,250
6
1,200
2,400
5,800
7
900
3,000
8
14,000
40,000
Days Per
Year


250
250
250
250
250

250
250
250

350

250

240
240
240

240
240

250
250
Utilization
Rate
(%)

85
85
85
85
85

85
85
85

85

85

75
75
75

90
90

75
75
Hides Per
Year


21,250
85,000
191,250
318,750
637,500

21,250
132,812
318,750

892,500

903,125

216,000
432,000
1,044,000

194,400
648,000

65,625
187,500
Square Feet
Per Year


850,000
3,400,000
7,650,000
12,750,000
25,500,000

850,000
5,312,500
12,750,000

35,700,000

7,225,000

1,440,720
2,881,440
6,963,480

1,296,650
4,322,160

2,625,000
7,500,000
Number of
Employees


30
60
85
150
355

40
120
165

120

39

20
40
97

30
100

15
30

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                           B.   Investment

The estimated book value and salvage value for each tannery model  are
shown in Table  29.   Also  shown  are  current  assets,  current liabilities,
net working capital, total invested  capital  and estimated replacement
value.

Book Value of Assets

The book value of a tannery's  assets represents the acquisition costs
of the various assets.  As would be  expected in an industry with a
substantial number of older plants and equipment, the book values  of
the model's assets do not reflect significant amounts.   However, the
book value does reflect the amount of capital the tannery owners have
invested in assets and accordingly represent a portion of what is
used as a basis for determining the  return on the owners equity.

Operating Capital

The models' operating capital  is defined as that capital necessary to
maintain the day to day operations of the tanneries.  Included in  the
computation of operating capital are a firm's current assets and current
liabilities.  Current assets represent those assets a firm maintains that
could be converted relatively easy into cash.  Current assets include such
items as raw materials inventory, finished product inventory and accounts
receivable.

As can be seen in Table  29, current assets  for the models represent a
sizeable amount.  This is due to the substantial quantities of hides and
leather that tanneries must maintain in their facility at any given time
in order to assure continuous operation.  This reflects a sizeable addi-
tional investment requirement to the tanneries owners.

Current liabilities represent those liabilities that a firm holds that
could be demanded to be paid within a short time period.  Current liabil-
ities include short term notes, accounts payable and wages payable.

The difference between current assets and current liabilities represent
the firm's operating capital or as it is sometimes called, net working
capital.  Net working capital represents the quantity of capital that the
firm  is required to maintain just to maintain daily cash balances.  Thus
it represents an investment requirement to the tanneries' owners.

Total Invested Capital

Total invested capital is the sum of the book value of assets and the net
working capital.  It represents the total amount of capital that is re-
quired to be invested in an operation by the owners.  Accordingly the
total invested capital represents the investment amount utilized for de-
termining a firm's return on investment.
                                  82

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                        Table
                         29.
The Leather Tanning Industry, representative model plants
        investment characteristics
00
CO
Model /Size

Cattle-Chrome
X-Small
Small
Medium
Large
X-Large
Cattle-Vegetable
Small
Medium
Large
Capacity
(Units/Day)

100
400
900
1,500
3,000

100
625
1,500
Fixed
Assets



291.0
448.0
1,080.0
1,995.0
3,990.0

230.0
415.6
870.0
Current
Assets



269.0
772.0
1,467.0
2,895.0
5,790.0

500.0
2,487.5
3,390.0
Current
Liabilities
______________ i


205.3
371.2
819.6
1,258.7
2,517.4

170.0
787.5
1,080.0
Net Working
Capital
r ci fino ^
^ pi ,UUU J

63.7
400.8
647.4
1,636.3
3,272.6

330.0
1,700.0
2,310.0
Total Invested
Capital



354.7
848.8
1,727.4
3,631.3
7,262.6

560.0
2,115.6
3,180.0
Salvage
Value



121.9
490.4
863.4
2,035.3
4,070.6

376.0
1,783.1
2,484.0
Cattle-to-Blue
  Large

Cattle-Splits
  Medium

Sheepskins
  Small
  Medium
  Large

Shearlings
  Small
  Large

Finishers
  Medium
  Large
                          3,000


                          4,250
                          1,200
                          2,400
                          5,800
                            900
                          3,000


                         14,000 ft.2
                         40,000 ft.2
   2,510.0   3,650.0
     233.8
      72.0
     201.7
     557.1
     648.3
   2,161.1
      94.7
     189.3
701.2
 60.0
120.0
290.0
 90.0
300.0
 42.0
126.0
          1,590.0
340.0
 48.0
 96.0
232.0
 36.0
120.0
 21.0
 63.0
2,060.0


  361.2
   12.0
   24.0
   58.0
   54.0
  180.0
   21.0
   63.0
4,570.0
595.0
1,184.0
384.6
   84.0
  225.7
  615.1
  702.3
2,341.1
  115.7
  252.3
 19.2
 44.2
113.7
118.8
396.1
 43.1
107.3

-------
Total invested capital requirements for the model tanners range from
$84,000 for a small sheepskin tannery to nearly $7.3 million for the
extra-large cattlehide chrome tannery.  Each model's total invested
capital requirement is depicted in Table 29.

Salvage Value

The salvage value of the model tanneries represents the amount of money
that the owners could recover should the tannery cease operation.  This
value will vary widely from plant to plant, depending on the age of the
facility and its condition and the use ability of the equipment as well
as the location of the plant.  In some instances the salvage value of
old, obsolete plants will be equal to the site value plus the scrap
value of the equipment.

There exist only a limited market for certain types of used machinery
and equipment.  Thus most of a closing plant's equipment would be
scraped.

Data are not available depicting the salvage value of tanneries.  Accord-
ingly after discussions with industry members it was determined that salvage
values for most tanneries would range between 10 and 20 percent of the
tannery's fixed assets plus its net working capital.

              C.  Model Plant Capacity and Utilization

As tanneries vary from one to another, there appears to be no industry
rule by which the models' capacity or utilization can be accurately des-
cribed.  For most tanneries their constraining factor is the number and
capacity of their drums (or for some tanners, the number and capacity of
their pits).

Commonly, tanneries will operate 5 days per week for 240 to 250 days per
year.  Furthermore, their utilization rates vary for the different types
of tanneries, however usually the rates range between 75 and 90 percent
of the tanneries' capacity.  The capacity and utilization rates for each
of the representative model plants were depicted in Table  28.

                  D.  Annual Sales of Model Plants
Annual sales of the model plants were determined utilizing the production
characteristics described in Table 28 as well as estimates of final
produc  p'^'ces.  Prices were estimated to be reflective of the average
grade and quality of leather within each tannery type.  Prices are repre-
sentative of late 1975 early 1976.

The prices utilized in this analysis are depicted below:
                                  84

-------
         Type
    Pri ce
       Source
Cattlehide, Chrome
Cattlehide, Vegetable
Cattlehides to the Blue

Cattle, Splits
Sheepskins
Shearlings
Leather Finishers
  (on contract)
$ .86/sq. ft.
$ .94/sq. ft.
$ .508/sq. ft.

$ .234/sq. ft.
$ .726/sq. ft.
$1.15/sq. ft.
$ .15/sq. ft.
Wholesale Price Index
Cattle & Kip Sides, Smooth
Oct.-Dec. 1975 Average
From industry surveys
From industry surveys and
 contacts
From industry surveys
From industry surveys
From industry surveys
From industry contacts
The annual sales for each of the tannery models are shown in Tables
30 through 33.

                 E.  Cost Structure of-Model Plants

The cost structures for each tannery model are depicted in Tables 30,
31, 32, and 33.   The major cost items are discussed below.

Raw Material
Raw materials for purposes of this analysis consisted entirely of raw
cattle hides or splits, or sheep skins or pelts.  Raw cattlehides are
sold by slaughterhouses on a poundage basis and this analysis assumed
the average hide weighed 55 pounds.  Prices utilized reflected the
October through December 1975 average price for Chicago Native Heavy
hides.  The price was 28.7 cents per pound.

The price utilized for raw cattle splits was determined from industry
surveys and is estimated to be $.72 per split.

Raw sheepskin prices were assumed to be $1.75 per skin.  These would
be received in the pickled state.  The price for sheep pelts was
estimated to be $4.00 per pelt.  Both the sheep skin and sheep pelt
prices were estimated utilizing the industry surveys.

Since the leather finishers are on a contract basis, they normally do
not experience raw material costs associated with the purchase of hides,

Labor

Labor costs were developed using the estimated number of employees for
each model plant multiplied times an estimate of the annual costs per
employee.  These costs were developed from industry provided data and
reflect varying wages for different types and sizes of tanneries.
                                 85

-------
        Table 30.  The Leather Tanning  Industry,  Representative Model Plants'  Costs  Characteristics  for'the  Cattlehlde
                   Chrome Tanneries.
00



Extra Small

SALES
COSTS
Raw Hides
Labor
Tan Materials &. Other
TOTAL
CASH EARNINGS
LESS
Depreciation
Interest
PRE-TAX INCOME
INCOME TAX
AFTER-TAX INCOME
1000
Dollars
$731.0
335.4
189.0
138.2
662.6
68.4
17.5
11.0
39.9
8.3
31.6
Percent
100.0
45.9
25.8
18.9
90.6
9.4
2.4
1.5
5.5
1.2
4.3

r
Small
1000
Dollars
$2,924.0
1,341.7
452.4
825.8
2,619.9
304.1
64.3
29.2
210.6
87.6
123.0
Percent
100.0
45.9
15.5
28.2
89.6
10.4
2.2
1.0
7.2
3.0
4.2
ATTLEHIDE CHROME TAN
Medium
1000
Dollars
$6,579.0
3,018.9
688.5
2^246.6
5,954.0
625.0
131.6
85.5
407.9
182.3
225.6
Percent
100.0
45.9
10.5
34.1
90.5
9.5
2.0
1.3
6.2
2.8
3.4
MCDTCC

Large
1000
Dollars
$10,965.0
5,031.5
1,303.5
3,741.9
10,076.8
888.2
185.4
109.7
592.1
270.7
321.4
Percent
100.0
45.9
11.9
34.1
91.9
8.1
1.7
1.0
5.4
2.5
2.9


Extra Large
1000
Dollars
$21,930.0
10,063.0
3,124.0
6,440.0
19,627.4
2,302.6
372.8
219.3
1,710.5
807.5
903.0
Percent
lobrcr-
45.9
14.2
29.4
89.5
10.5
1.7
1.0
7.8
3.7
4.1
      CASH  FLOW
49.2
6.7
187.3
6.4
357.2
5.4
507.8
4.6
1,275.8     5.8

-------
CO
              Table 31.   The Leather Tanning Industry,  representative model  plants'  costs characteristics  for the cattlehide vegetable
                                      tanneries,  the cattlehide blue tannery  and the  cattlehide split tannery


SALES
COSTS
Raw Hides
Labor
Tan Materials & Other
TOTAL
CASH EARNINGS
LESS
Depreciation
Interest
PRE-TAX INCOME
INCOME TAX
AFTER-TAX INCOME
CASH FLOW

Sma
($000)
799.0
335.4
293.0
106.7
7357T
63.9
14.4
1.6
47.9
10.0
37.9
52.3

Vegetable
Tanneries
11 Medium
(%)
100.0
42.0
36.7
13.3
92TO~
8.0
1.8
0.2
6.0
1.3
4.7
6.5
($000)
4,993.7
2,096.4
879.0
1,673.7
4,649.1
344.6
74.9
25.0
244.7
104.0
140.7
215.6
(X)
100.0
42.0
17.6
33.5
93TT
6.9
1.5
0.5
4.9
2.1
2.8
4.3


Large
($000)
11,985.0
5,031.4
1,523.8
4,854.5
11,409.7
575.3
143.8
155.8
275.7
118.9
156.8
300.6
(X)
100.0
42.0
12.7
40.5
9572"
4.8
1.2
1.3
2.3
1.0
1.3
2.5
Cattle-
to-Blue
($000)
18,150.0
• 14,235.0'
1,267.0
1,527.0
17,029.0
1,121.0
186.0
74.0
861.0
400.0
461.0
647.0
(X)
100.0
78.4
7.0
8.4
53T8~
6.2
1.0
0.4
4.8
2.2
2.6
3.6
Split
Tannery
($000)
1,690.7
650.3
280.0
614.2
1,545.3
145.4
30.4
16.9
98.1
33.6
64.5
94.9
• IX)
100.0
38.5
16.6
36.3
91.4
8.6
1.8
1.0
5.8
2.0
3.8
5.6

-------
         Table  32.  The Leather Tanning Industry, Representative Model  Plants'  Costs Characteristics for the Sheep and Shearling
                   Tanneries.
00
CO



Small

SALES
COSTS
Raw Skins or Pelts
Labor
Tan Materials & Other
TOTAL
CASH EARNINGS
LESS
Depreciation
Interest
PRE-TAX INCOME
INCOME TAX
AFTER-TAX INCOME
1000
Dollars
. 1046.0
378.0
160.7
459.2
997.9
48.1
10.5
3.1
34.5
7.1
27.4
Percent
100.0
36.1
15.4
43.9
95.4
4.6
1.0
0.3
3.3
0.7
2.6
-SHEEPSKIN TANNERIES-
Medium
1000
Dollars
2091.9
756.0
321.4
905.7
1983.1
108.8
20.9
10.5
77.4
23.7
53.7
Percenl:
100.
36.
15.
43.
94.
5.
1.
0.
3.
1.
2.
0
1
4
3
8
t*
(,
0
5
7
1
6


Large
1000
Dollars
5055.5
1827.0
779.4
1948.6
4555.0
500.5
50.5
50.6
399.4
178.2
221.2
Percent
100.0
36.1
15.4
38.5
90.0
10.0
1.0
1.0
7.9
3.5
4.4

Sma
1000
Dollars
1491.2
777.6
272.3
214.6
1264.5
226.7
44.8
37.3
144.6
55.9
88.7
SHEARLING
11
Percent
100.0
52.1
18.3
14.4
84.8
15.2
3.0
2.5
9.7
3.8
5.9
TANNERIES-
Lar
1000
Dollars
4970.5
2592.0
907.7
715.3
4215.0
755.5
149.1
124.3
482.1
217.2
264.9

ge
Percent
100.0
52.1
18.3
14.4
84.8
15.2
3.0
2.5
9.7
4.4
5.3
      CASH FLOW
37.9
3.6
74.6
3.6
271.7
5.4
133.5
8.9
414.0
8.3

-------
     Table 33.   The Leather Tanning Industry, representative model
      plants'  costs characteristics for the leather finishers
      Financial
        Item
SALES

COSTS
  Raw Hides
  Labor
  Finishing Chemicals
  Other

    TOTAL

CASH EARNINGS

LESS
  Depreciation
  Interest

PRE-TAX INCOME
INCOME TAX
AFTER-TAX INCOME

CASH FLOW
     Leather Finishers (on coi•:ract)
     Medium.Large
($000)

394.0
100.0
($000)

1,125.0
100.0
162.0
135.0
78.0
375.0
19.0
41.0
34.0
20.0
95.0
5.0
324.0
400.0
288.0
1,012.0
113.0
28.8
35.6
25.6
90.0
10.0
8.5
3.9
6.6
1.3
5.3
2.2
1.0
1.8
0.3
1.5
16.9
9.0
87.1
28.3
58.8
1.5
0.8
7.7
2.5
5.2
 13.8
  3.7
   75.7
  6.7
                                  89

-------
For the cattlehide chrome tanneries annual per employee labor costs
ranged from $6,300 for the extra small model to $8,800 for the extra
large model.  For the cattle hide, vegetable tanneries annual labor
costs were estimated to be $7,325 per employee for the small and medium
model and $9,235 for the large tannery model.  Labor costs for split
tanners were estimated to be $7,200 per year; cattle-to-blue tannery,
$8,000 per year; for sheepskin tanners, $8,035; for shearling tanners,
$9,200 per year; and for leather finishers, $9,000 per annum.

Tanning Materials and Other Costs

This cost classification includes expenditures for materials used in
the tanning process, miscellaneous other direct costs as well as in-
direct costs (i.e., administrative expenses).  These costs vary consid-
erably for different tanneries and for the models.  For cattlehide and
sheepskin tanners, they ranged between 13.3 and 43.9 percent of sales.
Leather finishers relative cost for such items were even higher, ranging
from 54.0 to 61.2 percent of sales.  This high percent is because of
the absence of raw material costs in most leather finishing operations.

Depreciation and Interest

Estimates of model tanneries' depreciation and interest were developed
from industry as well as Internal Revenue Service data.  The deprecia-
tion amounts utilized in this analysis are depicted in Table  34.   In
this table depreciation is expressed as a percent of sales as well as
fixed assets.  In terms of sales depreciation represents between 1.0
and 3.0 percent.  Expressed as a percentage of fixed assets deprecia-
tion represents between 1.0 and 18.0 percent.  This wide variation in
depreciation as a percent of fixed assets is reflective of the wide
variation of plant and equipment composition that exists in the industry.

Interest charges for the model plants, expressed as a percent of sales,
are also shown in Table  34.   Interest charges  ranged from 0.2 percent
of sales to 2.5 percent.

Total Costs

Raw hides or skins costs ranged from 36.1 percent of sales for the
sheepskin tanneries to 52.1 percent for the shearling tanneries.  The
cattle tanneries raw hide costs approximated 40 percent.  Labor costs
ranged from 10.5 percent of sales for the medium cattle chrome tannery
model to 36.7 percent for the small cattle vegetable model.  The majority
of the models'1 labor costs represented 10 to 20 percent of sales, except
for leather finishers where labor costs represent 30 to 40 percent of
sales.  Finally expenditures for tanning materials and other direct and
indirect costs ranged from 13.3 percent for the small cattle vegetable
model to 43.9 percent of sales for the small cattle chrome tannery
model to 61.2 percent for a large leather finisher.

As previously mentioned these costs are depicted for all the models on
Table 30 through 33.  Total costs of all the models, including
depreciation and interest, represent between 90.3 percent and 97.7
percent of sales.  This would result in a pre-tax income range of 2.3
to 9.7 percent.

                                 90

-------
        Table 34.   The Leather Tanning Industry, representative
                model plant depreciation and interest
                               Depreciation
   Model/Size
Percent of
  Sales
 Percent of
Fixed Assets
  Interest
as a Percent
  of Sales
Cattle-Chrome
  X-Small
  Small
  Medium
  Large
  X-Large

Cattle-Vegetable
  Small
  Medium
  Large

Cattle-to-Blue
  Large

Cattle Splits
  Medium

Sheepskins
  Small
  Medium
  Large

Shearlings
  Small
  Large

Finishers
  Medium
  Large
   2.4
   2.2
   2.0
   1.7
   1.7
   1.8
   1.5
   1.2
   1.0
   1.8
   1.0
   1.0
   1.0
   3.0
   3.0
   2.2
   1.5
  •Percent-


     6.0
    14.4
    12.2
     9.3
     9.3
     6.3
    18.0
    16.5
     7.4
    13.0
     1.4
     1.0
     1.3
     6.9
     6.9
     9.0
     8.9
    1.5
    1.0
    1.3
    1.0
    1.0
    0.2
    0.5
    1.3
    0.4
    1.0
    0.3
    0.5
    1.0
    2.5
    2.5
    1.0
    0.8
                                  91

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                   F.  Model Plant Annual Profits

After-tax income, pre-tax and after-tax return on sales and return
total invested capital for the various model tanneries are shown in
Table 35.  These profitabilities reflect late 1975 conditions.  As
shown in the table the models' return on sales, after-tax, range from
1.3 percent to 5.9 percent.  After-tax return on total invested capital
range from 2.1 percent to 23.3 percent.

                        G.  Annual Cash Flows

Estimated annual cash flows for the different types and sizes of model
tanneries are depicted in Table 36.  Cash flow, as calculated, repre-
sents the sum of after-tax income plus depreciation.  In the table it
is shown in actual dollars as well as expressed as a percent of sales
and total invested capital.
                                  92

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          Table 35.   The Leather Tanning Industry, representative
                        model plant profitability

Model /Size

After-Tax
Income
rsnnm
Return of Sales
Pre-Tax After-Tax

Return of Total
Invested Capital
Pre-Tax After-Tax
ont> 	
Cattle-Chrome
  X-Small             31.6
  Small              123.0
  Medium             225.6
  Large              321.4
  X-Large            903.0

Cattle-Vegetable
  Small               37.9
  Medium             115.3
  Large              156.8

Cattle-to-Blue
  Large              461.0

Cattle Splits
  Medium              64.5

Sheepskins
  Small               27.4
  Medium              53.7
  Large              221.2

Shearlings
  Small               88.7
  Large              264.9

Finishers
  Medium               5.3
  Large               58.8
5.5
7.2
6.2
5.4
7.8
6.0
4.9
2.3
4.8


5.8
3.3
3.7
7.9
9.7
9.7
1.8
7.7
4.3
4.2
3.4
2.9
4.1
4.7
2.8
1.3
2.6


3.8
2.6
2.6
4.4
5.9
5.3
1.5
5.2
11.3
24.8
23.6
16.3
23.6
 8.6
11.6
 8.7
18.8


16.5
 4.1
 3.4
 6.5
20.6
20.6
 5.7
34.5
 8.9
14.5
13.1
 8.9
12.4
 6.8
 6.7
 4.9
10.1


11.0
 2.1
 2.4
 3.0
12.6
11.3
 4.6
23.3
                                    93

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       Table  36.   The Leather Tanning Industry, representative model
                             plant cash flow



Model /Size

Cattle-Chrome
X-Small
Small
Medium
Large
X-Large
Cattle-Vegetable
Small
Medium
Large


Annual
Cash Flow
($000)

49.2
187.3
357.2
507.8
1,275.8

52.3
215.6
300.7

Cash Flow
as a Percent
of Sales



6.7
6.4
5.4
4.6
5.8

6.5
4.3
2.5
Cash Flow
as a Percent
of Total
Invested Capital



13.9
22.1
20.7
14.0
17.6

9.3
10.2
9.5
Cattle-to-Blue
  Large

Cattle Splits
  Medium

Sheepskins
  Small
  Medium
  Large

Shearlings
  Small
  Large

Finishers
  Medium
  Large
647.0


 94.9
 37.9
 74.7
271.7
133.4
414.0
 13.8
 75.7
3.6
5.6
3.6
3.6
5.4
8.9
8.3
3.7
6.7
14.2


16.0
 3.4
 3.3
 4.4
19.0
17.7
11.9
30.0
                                 94

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                 VII.  HAZARD WASTE MANAGEMENT COSTS


Hazardous waste management requirements and costs depicted in this chapter
were provided by the Hazardous Waste Management Division, Office of Solid
Waste of the Environmental Protection Agency as developed by the technical
contractors Battelle Columbus Laboratories I/ and SCS Engineers, Inc. 2_/.
These studies contained the basic data on hazardous waste management,
which were expanded to apply to all the alternative model plants developed
in the previous chapter.


    A.  Hazardous Waste Management Guidelines and Recommendations


Specific government guidelines are currently unavailable for either iden-
tification of hazardous waste or treatment and disposal  technology.  Thus,
the technology, proposed so far, represents a state-of-the-art level  which
is selected as "an environmentally acceptable disposal  technology" for
various "hazardous" waste streams.  Such technology is  currently classified
as Pathways Level III (PAIII) technology.  In light of  the lack of guide-
lines, the actual PAIII facilities and costs analyzed in this report are
preliminary as they may be revised after regulations and guidelines are
finally adopted 3/.


  B.  Hazardous Waste Management Treatment and Disposal  Technology

The bulk of tanneries' solid waste stream is comprised of pieces of  leather
from various plant operations and wastewater treatment sludge.  For  non-
vegetable tanners, most of this waste stream will contain hazardous  waste,
primarily trivalent chromium with some lead, zinc and copper.  As stated
earlier, vegetable tanners will usually not produce hazardous waste.

According to the treatment and disposal cost study, the PAIII technology for
the hazardous waste stream generated by the leather tanning and finishing
industry will be a secured landfill 4/.  This is the compatible technology
for a waste stream containing hazardous solid and sludge waste.

The secure landfill (sometimes referred to as a "secure chemical landfill"
or a "chemical landfill"), as designated in this report, is one that will
provide complete long-term protection for the quality of surface and sub-
surface waters from hazardous waste deposited therein and against hazards
to public health and the environment.
 II  Battelle Columbus  Laboratories,  Cost of Complying with Hazardous Waste
     Management  Regulations,  Draft  Report,  Environmental  Protection Agency,
     Contract No.  68-01-4360,  Columbus,  Ohio, October 12,  1977.

 2/  SCS Engineers,  Inc.,  Assessment  of  Industrial  Hazardous Waste Practices--
     Leather Tanning and  Finishing  Industry, Environmental Protection Agency,
     Report No.  PB-261018, Reston,  Virginia, November 1976.

 3/  Battelle, op.  cit..  pp III-l  to  III-2.

 4/  Ibid., p VI-7.
                                     OK

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The secure landfill has special features beyond those possessed by "sanitary"
or "approved sanitary" landfills which enable it to handle hazardous wastes
in an environmentally adequate manner.  Some of the special features or
criteria required for secure landfills are presented below:

      . Secure landfill sites should be located or engineered to avoid
        direct hydraulic continuity with surface or sub-surface waters.
        If there is potential for hazardous wastes to percolate or leach
        to ground water, then the use of impermeable barriers, such as
        clay, special concrete, plastic and other liners, will be required
        to accomplish suitable containment and isolation of wastes.

      .  Facilities for leachate collection and treatment are essential
        for liquid, low-solids slurries, sludges, or other wastes from
        which soluble constituents  might be leached.  Leachate may be
        collected by the use of suitable piping at the bottom of the
        cell and a sump pump.  After suitable treatment, any dewatered
        solids can be returned to the disposal site and the effluent
        can be discharged to a sewer or stream.

      .  Surveillance and monitoring of the disposal site, including regular
        analysis of ground and surface waters for changes in background
        levels, are necessary.

      .  The composition and volume of each extremely hazardous waste is
        known.  Care is taken to segregate wastes to prevent potentially
        dangerous reactions.  The location of specific wastes in the
        cells is recorded and mapped.  Neutralization,.chemical fixation,
        encapsulation, and other pretreatment techniques are often necessary
        prior to burial of some wastes in a secure landfill.I/


          C.  Status of Industry Hazardous Waste Management


Most tanneries dispose hazardous waste in conventional sites including dumps,
landfills, trenches and lagoons.  A recent study covering 136 tanneries,
showed 8 percent used open dumps, 73 percent used landfills, 18 percent
disposed of waste in trenches or lagoons and one tannery utilized agricul-
tural  spreading.   The 136 tanneries were serviced by 23 disposal  sites of
which eight were publically owned and served 52 tanneries, five tanneries
owned their own sites and 10 sites serving 56 tanneries were privately
owned.  Thus 79 percent of the tanners use privately or publically owned
sites while 21 percent maintain company sites.  Of the 23 disposal sites,
only 2 were state certified to accept hazardous waste.2/
I/ Ibid., pp 37 and 38.
21 SCS Engineers, Inc., op. cit., p. 138.

                                  96

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After tanners finally adopt requirements for hazardous waste management
regulations, the prior distribution of management techniques will change
as some of the current disposal sites would not be approved to handle
solid waste.  However, at this time the extent of the shift cannot be
estimated.

                 D.  Hazardous Waste Management Costs

Hazardous waste management costs are based on the industry waste stream
category, Pathways Level III technology applied, and level of waste
generated, as provided from studies by EPA contractors listed previously.

Costs depicted and discussed in this section, apply only to the treatment
and disposal of solid and sludge waste in a PAIII technology, specifically
secure landfill.  Costs supplied by the EPA cost contractor are an industry
average to cover contract hauling and disposal.  For the Leather Tanning
and Finishing Industry, this cost was estimated to average $55 per metric
ton per year for any plant in the industry.  In the EPA study, no allowances
were included for plant location, size, or process.  As some disposal costs
exist prior to adoption of PAIII technology, the impact must be assessed on
the incremental cost increases, which according to the same report equal $37
per metric ton per year.

Costs are expressed in January 1, 1977 dollars.  They are costs for a
service rendered for which little or no investment costs will usually
be incurred.

Yearly costs for various types of plants will vary depending on volume of
waste generated.  This is estimated for model plants based on documented
average potentially hazardous solid waste produced per thousand equivalent
hides processed!/ times hides processed annually.  As there are no assumed
investment costs, neither depreciation nor interest costs on investment
will be generated.  Total annual costs and costs per 1,000 equivalent
hides produced are shown in Table 37.
j_/ SCS Engineers Inc., op. cit., pp. 61-121

                                  97

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            Table 37. •  Hazardous  waste treatment and  disposal  costs for leather tanners and finishers based •
                         on  incremental  costs  of $37  per MT I/
00





Type of tanner




Volume of
production
per day



Annual
equivalent
hide
production?/
(1,000)

P.H.W. 3/
M.T per
1,000
equiv.
hides
(1977
levels)

Incremental
costs per
1,000 equiv.
hides
$


Total
annual
incremental
costs


Cattlehide - pulp chrome
X-small
Small
Medium
Large
X-Large
Cattlehide - blue
Cattle-splits
Sheepskins
Small
Medium
Large
Shearlings
Small
Large
Leather Finisher
Medium
Large
100 hides
400 hides
900 hides
1,500 hides
3,000 hides
3,000 hides
4,250 splits

1,200 skins
2,400 skins
5,800 skins

900 pelts
3,000 pelts

14,000 sq ft
40,000 sq ft
21.3
85.0
191.3
318.8
637.5
893
180.6

36
72
174

32.4
108.1

65.6
187.5
4.9
4.9
4.9
4.9
4.9
10.0
8.6

1.66
1.66
1.66

1.66
1.66

0.16
0.16
181
181
181
181
181
370
318

61
61
61

61
61

6
6
3,860
15,380
34,630
57,700
115,390
330,410
57,430

2,200
4,390
10,610

1,980
6,590

390
1,120
          I/  Pathway Level  III  cost less current treatment and disposal costs:  $55/MT - $18/MT = $37/MT

          2J  Equiv.  hide =  40 sq ft,  split  =  8  sn,  ft  and  sheepskin  =  6.67 sq ft

          3_/  P.H.W.  -= Potentially Hazardous Waste

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                  VIII.  ECONOMIC IMPACT ANALYSIS


The resulting direct impacts arising from hazardous waste management
regulation for the Leather Tanning and Finishing Industry are expected
to vary for different types, however, the overall industry impacts should
be minor.  The assumed control technology to meet regulations is disposal
in secured landfills, Pathways Level III technology.  Little or no invest-
ment will be required relative to this disposal method and essentially
all impacts will originate  from increased operating costs to pay for
collecting, hauling and disposing of the waste stream.  Some of these
costs would be incurred without regulation as most of the hazardous waste
is currently being disposed of in landfills and/or dumps but charges for
use of these facilities are significantly less than for secured landfills.
Ultimately, the impact analysis will assess the incremental or change in
costs to go from present technology to regulation required technology,
secured landfills.

This chapter will address itself to the various types of impacts for
each of the different tannery categories that produce hazardous waste.
As vegetable tanners do not generally produce significant amounts of
hazardous waste, they will be excluded from the impact analysis.  This
results in an impacted industry that potentially could include about
220 plants based on 1976 data.  The impacts on these plants will be
simulated by applying added costs to the model tanneries described in
Chapter VI.  The impacts are based on the production and financial
characteristics of the models and the waste management costs as pre-
sented in Chapter VII.

                         A.  Price Effects

Required Price  Increases

An implicit indication of the expected price effects of hazardous waste
management regulations used in this report is the amount of sales price
increase necessary to maintain a tannery's profitability, after related
regulation expenditures, equal to profits before the regulation.  The
method of computation was described in Chapter II (Methodology), Section
F, of this report.  The ability to actually pass on such costs is evaluated
in the next section.

The amount of sales price increases necessary to offset the estimated hazardous
waste management costs for the model tanneries are shown in Table 38.
Note that the required increases are estimated to be constant for all sizes
of plants.   This reflects the assumption by the technical contractor for
EPA that costs per metric ton of waste are constant for plants producing
a waste stream disposed in secured landfills.  Also shown in the table are
the sensitivity ranges of required price increases when costs vary +20
percent of original estimated management costs.!/
!_/ After the +20 percent sensitivity test was reviewed, the sensitivity
   analysis for thru-to-blue and split tanners was expanded to +40 percent
   to obtain additional information on the financial vulnerability of these
   more highly impacted segments.  Some of the results of the +40 percent
   test are included in the text but not in the tables.
                                   oo

-------
   Table 38.   Required price increases necessary to offset hazardous waste
               management costs for the Leather Tanning and Finishing Industry
      Model plant segment
  Required price increase (%)
% of proposed waste management
80           100          120
Cattlehide - chrome (all sizes)
Cattlehide - thru-to-blue
Cattlehide - splits
Sheepskins (all sizes)
Shealings (d.o.)
Leather finishers (d.o.)
0.4
1.5
2.7
0.2
0.1
0.1
0.5
1.8
3.4
0.2
0.1
0.1
0.6
2.2
4.1
0.3
0.2
0.2
                                  100

-------
The required price increase for cattlehide chrome tanneries are 0.5
percent of the recent price level.  Plants tanning cattlehides thru-
to-blue will require price increases of about 1.8 percent of recent
prices to maintain profits.  Cattlehide split tanners would need to
increase prices 3.4 percent while sheepskin,, shearling and leather
finishing operations would require price increases of 0.2 percent or
less.

Based on estimated costs, the industry would generally not require major
price increases to maintain profits.  However, thru-to-blue and, in
particular, split tanneries would require significant price increases.
These higher levels reflect the fact that their product value is lower
than other tanning segments and for split tanneries, their waste generated
per unit of product is much higher than other, types of tanneries.

Expected Price Increase

The Leather Tanning and Finishing Industry is an extremely competitive
industry in which tanners operate on small profit margins.  Primarily
because of the strong competition from non-impacted foreign tanners,
domestic tanners will have little success in passing on significant
price increases to recover costs specifically generated by new waste
management regulations.  Also, since the percent of the required price
increase that can likely be passed on is relatively small, it is difficult
to measure with given historical data shortages and limited forecasting
techniques.  Fortunately, most of the required price increases are small,
except for split tanneries, and represent a nominal portion of prices.

Split tanners face the highest relative impacts when considering required
price increases.  This is the result of two factors.  First, their waste
loads are high.  Second and most important, they generally produce a lower
priced product.  In this study, split leather was valued at less than 25tf
per square foot whereas chrome tan cattlehide leather was valued at 86<£
per square foot (approx. 1975 price levels).  Thus, a 3.4 percent required
price increase represents only about $.008 per square foot in absolute
costs.  The ability of the split tanners to pass this $.008 per square
foot on to consumers will depend on demand for their product, competition
from foreign leather and leather goods, sales effectiveness of tanners, and
competition from synthetics.   These variables cannot be estimated but in
general it is believed that split tanners will be able to pass on less
than half of the costs which would increase the costs of splits less than
$.004 per square foot.
                                  101

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                       B.  Financial Effects

Based on model tannery profiles described in Chapter VI and the estimated
costs of waste management regulations provided by EPA, the following
financial indicators are computed under baseline (without costs of regu-
lations) and with costs of regulations:

    1.  After-tax income,
    2.  After-tax return on sales,
    3.  After-tax return on invested capital,
    4.  Cash flow,
    5.  Cash flow as a percent of invested capital,
    6.  Net present value.

The above are computed for each tannery model according to the discounted
cash flow (DCF) and return on investment (ROI) procedures outlined in
the methodology chapter, Chapter II.  Furthermore, a sensitivity analysis
is performed for each model using hazardous waste management cost estima-
tes at levels of 80 and 120 percent of those provided by EPA.

The results of the model tannery analysis of the recommended pretreatment
standards are summarized in Tables 39, 40, and 41, for each tannery model.
The results are described below for each category of tannery models.

Cattlehide, Chrome

After-Tax Income.  As shown in Table  39, the costs for hazardous waste
management for cattlehide, chrome tannery models results in major to moderate
reductions in the five models' income depending on size of operation.

Expressed as  a percent  of  the  baseline  incomes,  the  costs  of  regulations
reduce  after-tax  incomes  by 22 percent  for  the  extra small model,  12
percent for  the small model,  11  percent for the  medium model,  12 percent
for  the large model,  and 7 percent  for  the  extra large model.

Return  on Sales.  As  would be  expected  with the  above indicated  declines
in after-tax  incomes, the  impacted  models'  returns on sales  declined  by
a corresponding percentage (Table 39).   The impacted models'  (extra
small through extra large) absolute declines of  returns  on sales range
from 0.7 percent  for  the extra small  model  to 0.3 percent  or  less  for
the  large and extra large  models.

Return  on  Invested Capital.   The baseline and impacted cattlehide,  chrome
tannery models' returns on invested capital  are  also shown in Table 39.
The  imposition of waste management  regulations  on these  models result in
their ROI's  being reduced  in  absolute percentages from 1.5 percent to 0.9
percent with  reductions again  decreasing as the  size of  model  increases.

Cash Flow.   Relevant  information concerning the  cattlehide,  chrome tannery
models'  cash  flows are  depicted  in  Table 40.  As  can be  seen  in  the
table,  the various models' cash  flows are reduced, however,  the reductions
are  not as great  as were  incurred by the models'  incomes.  For the models,
the  cash flows declined by as  much  as 12 percent for the extra small  model
to as little  as 5 percent  for the extra large model.


                               102

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                                      Table 39.  Impacts of hazardous waste management regulations,
                                                    Leather Tanning and Finishing Industry
After-tax
Segment/Model Size
Cattlehide - Chrome
X-Small
Small
Medium
Large
X-Large
Baseline
Case
32
123
226
321
903
Income ($000)
% of Proposed Waste
Management Costs
802
26
no
204
290
848
100%
25
108
201
284
836
120%
25
106
197
278
824
After-tax Return on Sales (%)
Baseline
Case
4.3
4.2
3.4
2.9
4.1
*
80%
3.5
3.7
3.1
2.6
3.9
of Proposed
Management
100%
3.5
3.7
3.0
2.6
3.8
Waste
Costs
1202
3.4
3.6
3.0
2.5
3.8
After- tax Return on Investment Capital (
Baseline
Case
8.9
14.5
13.1
8.9
12.4
*
80%
7.2
12.9
11.8
8.0
11.7
of Proposed Waste
Management Costs
1002M 1202
7.1 7.0
12.7 12.5
11.6 11.4
7.8 7.7
11.5 11.3
Cattlehitie - Thru to Blue
  Large                         461         317     282        248

Cattlhide - Splits
  Medium                         65          34      28         22

Sheepskins
  Small                          27          24      23         23
  Medium                         54          45      44         44
  Large                         221         210     209        208

Shearlings
  Small                          89          81       81         80
  Large                         265         254     254       253

Leather Finishers
  Small                           5           555
  Large                          59          51       51         51
2.5


3.8
2.6
2.6
4.4
5.9
5.3
1.3
5.2
1.7


2.0
2.2
2.1
4.1
5.4
5.1
1.2
4.6
1.6


1.6
2.2
2.1
4.1
5.4
5.1
1.2
4.6
1.4


1.3
2.2
2.1
4.1
5.4
5.1
1.2
4.5
10.1


10.8
32.6
23.8
36.0
12.6
11.3
 4.6
23.3
 6.9


 5.7
28.0
19.9
34.1
11.5
10.9
 4.2
20.3
 6.2


 4.6
27.7
19.7
33.9
11.5
10.8
 4.2
20.3
 5.4


 3.6
27.5
19.5
33,7
11.5
10.8
 4.1
20.3

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Table 40.  Impacts of hazardous waste management regulations on cash flows, Leather Tanning
                                and Finishing Industry

CASH FLOW ($000)
Segment/Model Size
Cattlehi de-Chrome
X-Smal 1
Small
Medi urn
Large
X-Large
Cattlehi de: Thru to
Large
Cattlehi de- Splits
Medium
Sheepskins
Small
Medi urn
Large .
Shearlings
Small
Large
Leather Finishers
Small
Large
Baseline
Case
^
49
187
357
508
1,276
Blue
647

95

38
75
272

134
414

14
76
% of
Proposed
Management
80%

43
174
336
477
1,221

503

64

34
66
260

126
404

13
68
100%

43
172
332
471
1,209

468

58

34
65
259

125
403

13
68
Waste
Costs
120%

42
171
329
465
1,197

434

52

34
65
258

125
402

13
68
CASH FLOW
AS % OF INVESTED CAP. (%)
% of Proposed Waste
Baseline
Case

13.9
22.1
20.7
14.0
17.6

14.2

15.9

45.1
33.1
44.2

19.0
17.7

11.9
30.0
Management Costs
80%

12.2
20.5
19.4
13.1
16.8

11.0

10.8

40.5
29.2
42.3

17.9
17.2

11.6
27.0
100%

12.0
20.3
19.2
13.0
16.6

10.2

9.8

40.2
29.0
42.1

17.9
17.2

11.5
27.0
120%

11.9
20.1
19.0
12.8
16.5

9.5

8.8

40.0
28.8
42.0

17.8
17.2

11.5
27.0

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Table 41.   Impacts of hazardous waste management regulations  on  net  present values, Leather
                           Tanning and Finishing Industry

Segment/Model Size
Cattlehi de-Chrome
X-Small
Small
Medium
Large
X-Large
Cattlehi de: Thru to Blue
Large
Cattlehide-Splits
Medium
Sheepskins
Small
Medium
Large
Shearlings
Small
Large
Leather Finishers
Smal 1
Large

Baseline
Case

199
788
1,682
1,687
5,820

3,514

283

222
441
2,107

826
2,613

39
427
NET PRESENT VALUES
($000)
% of Proposed Waste Management
80%

184
730
1,550
1,467
5,380

2,256

64

214
424
2.066

818
2,588

36
423
100%

181
715
1,517
1,412
5,270

1,941

10

212
420
2,056

816
2,582

36
422

Costs
120%

177
700
1,484
1,357
5,160

1,626

-45

210
416
2,046

814
2,576

35
420

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Cash flows as percents of invested capital  decline from as much as 1.9
percentage points for the extra small to 1.0 percentage points for the
extra large tannery model.

Net Present Values.  The net present values for the cattlehide, chrome
tannery models are" all positive in both the baseline case as well  as after
incurring expenditures for hazardous waste  management (Table 41).   This
implies that it would be probable that model tanneries could remain in
operation after meeting the regulations and remain financially stable,
assuming all other factors are constant.

Cattlehides - Thru to the Blue Tanneries

As  shown previously,  there are a limited number  of thru-to-blue tanneries,
three  known.   Furthermore, the operation of these plants  has  been sporadic
in  recent years with  plants closing down periodically due to  supply
shortages, operational  losses or changes of ownership.   Therefore,  the
impacts on the model  plant for these operations  must be  viewed cautiously
as,  at best,  they only reveal general  tendencies of impact levels for this
.highly fluctuating segment.  With this in  mind,  the estimated impacts show
the  possibility for significant declines in some financial  parameters.
After-tax income, return on sales, and return  on invested capital  could
decrease by over 35 percent (Table 39). Cash  flows are  estimated
to  be  reduced by about 28 percent and cash flows as a percent of  invested
capital will  drop from 14.2 percent to 10.2 percent.  The net present value  ,
 (Table  41) declines  but is still positive even  if costs are  40 percent  i-igher
than estimated..  Thus those plants that are in operation should be able  to
cover  waste management  costs.

Cattlehide Split Tanneries

Only one model  cattlehide  split  tannery was developed.  The imposition of
hazardous  waste management costs  on  this model reduces its base case  after-
tax  income from $65,000  to $28,000 with a  corresponding decrease  in its
returns on sale (from 3.8  to  1.6  percent).   This  reduction affects  the
models  return  on investment by decreasing  from 10.8 percent in the  base
case to 4.6 percent after  the imposition of waste  related  costs (Table
39).  These are  the largest impacts  incurred by  any model  plant as
split  tanneries waste loads are  the  second highest of  the  industry  and
they produce  the lowest  valued product.

As  shown in Table 40, the cattlehide split tannery's cash flow is
reduced from $95,000  to $58,000 after hazardous  waste management  regula-
tions.   This  results  in the cash flow expressed  as a percent  of invested
capital decreasing from 15.9  percent in the base case to 9.8  percent.

The  models net present  value  remains  positive  after hazardous  waste manage-
ment costs are incorporated into the  model.  However,  the  NPV  does  become
critically low, dropping from $283,000 to  $10,000  and  if  costs are  increased
20 and  40  percent the NPV  ranges  from.a negative  $45,000  to a  negative  	
$100,000.   Thus,  split  tanners will  be able  to maintain  minimum viability
on the  average but depending  on  costs, specific  plants could  be finan-
cially  theatened.
                                                                             t

                                    106

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Sheepskin Tanneries

Sheepskin tannery models were utilized to depict the no-beamhouse tannery
operations.   The resultant impacts of hazardous waste management costs  on
these models are generally low and are depicted below.

 After-Tax Income.  As  shown  in  Table  39,  the sheepskin tannery models'
 incomes  are reduced  by $4,000,  $10,000  and  $12,000  for the small, medium
 and  large models,  respectively.   These  reductions represent declines in
 income of 15 percent for  the small model  and 19  and 5 percent for the
 medium and  large models,  respectively.

 Return on Sales.   The  sheepskin tanneries'  returns  are reduced  from fairly
 low  levels  in the  base case  to  even lower levels.   After hazardous waste
 management,  the small  models return on  sales is  only 2.2 percent and the
 medium models is 2.1 percent.   The large  models' return is reduced from
 4.4  percent to 4.1 percent by the imposition of  regulations (Table 39).

 Return on Invested Capital.   Table 39 also  depicts  the sheepskin models
 return on invested capital both before  and  after hazardous waste management
 costs.   As  shown in  the table,  the returns  are reduced; however, the magni-
 tudes of the reductions are  not great and the  impacted returns  appear  to
 be relatively healthy  with the  past waste management returns being 27.7
 and  19.7 percent for the  small  and medium models and 33.9 percent for  the
 large model.

 Cash Flow.   The cash flows of the sheepskin models  are shown in Table  40.
 In actual dollars, the imposition of  hazardous waste management results in
 reductions  of $4,000 for  the small model, $10,000 for the medium model,
 and  $13,000 for the  large model.  'Compared  to  the respective amounts of
 the  models'  original cash flows,  these  reductions represent reductions
 of less  than 14 percent of the  models cash  flows.

 Cash flows  expressed as a percent of  total  invested capital are reduced
 from 45.1,  33.1 and  44.2  percent  to 40.2, 29.0 and  42.1 percent for the
 small, medium and  large sheepskin tannery models, respectively.

 Net  Present Values.  The  net present  values in the  base case are all
 positive with the  small models'  NPV being $222,000, the medium  model
 being $441,000 and the large models'  NPV  being $2,107,000.  After
 hazardous waste costs,  the NPV  are reduced  to  $212,000, $420,000, and
 $2,056,000  respectively (Table  41).

 Shearling Tanneries

 The  resultant model  tanneries'  impacts  on shearling tanneries  are  also
 generally low.  For  example, the small  shearling tannery model  will  incur
 a  reduction of 9 percent> or $8,000  of  its  base case incomes  by paying
 costs to dispose in  a  secure landfill.   This will  result  in  a  reduction
 of the models return on sales from  5.9  percent to  5.4 percent  and  the
 return on invested capital will decline from  12.6  percent  to  11.5  percent
 (Table 39).   The small models'  cash  flow will  decline by  $9,000 to an
 after control amount of $125,000 which  will result  in the  cash  flow as a
 percent  of  invested  capital  decreasing  from 19.0 percent  in  the base  case
 to 17.9  percent after  impacts (Table  40).  As  shown in  Table 41,
 the  models'  NPV,will decline from $826,000  in  the  base  case  to $816,000
 after incurring hazardous waste management  costs.
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The large shearling tannery models'  income will  decline by 4 percent from
$265,000 to $254,000 when hazardous  waste management regulations are met.
This will result in the models'  return on sales  to decrease from 5.3 to 5.1
percent and its return on invested capital to decrease from 11.3 to 10.8
percent (Table 39).   The models'  cash flow will  decline by only  $11,000
to an after controls amount of $403,000.   This cash flow reduction will
correspond to a decrease in its  cash flow expressed as a percent of in-
vested capital decreasing from 17.7  to 17.2 percent (Table 40).   The
large shearling tannery models net present value before hazardous waste
expenditures, its NPV is reduced by  1 percent to $2,582,000.


                         C.  Production Effects
The Leather Tanning and Finishing Industry can accurately be depicted as
having experienced a deteriorating phase until 1975 and 1976 at which time
total industry production increased for the first time in eight years.   Prior
to 1975, industry production dropped substantially each year from a peak
physical, volume of 32.4 million cattlehide equivalents in 1967.  The volume
in 1974 was less than 20 million cattlehide equivalents, or a decline of
38 percent from the peak year (1967).

Two  major  factors  have contributed  to  the decline experienced  by the
industry:

        1.   Increased  international  competition
        2.   Increased  competition  from  synthetic  leathers both  in
            terms  of  physical product and  price.

During  1975,  the  tanning industry experienced a  growth  situation which
resulted in the  industry's  annual production  to  increase from  less  than
20 million cattlehide equivalents in 1974 to  nearly 22  million by  the end
of 1975.   This growth situation was  partially resultant of  improvements
in the  domestic  tanners competitive  environment  as well as  increased de-
mand by consumers  for the natural look (i.e., leather).

Production of leather is dominated  by  the large  and medium  sized plants.
Thirty  one percent of the tanneries  are categorized as  large (or extra-
large)  and handle  approximately 68  percent of the industry's volume.  Twenty
one  percent of the tanneries are  categorized  as  medium  and  process  an esti-
mated 19 percent  of  the volume.   The remainder,  about 50 percent,  are small
or extra small operations which as  an  aggregate  produce only 13 percent
of the  total  industry volume.

Plant Closures

According  to  the  records of the Tanners'  Council  of America, 45 tanneries
have shut  down or ceased operation  between 1968  and 1975.   The reasons  for
these closures vary,  however,  some  of  the more important factors include:
                                  108

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       .   increased iinternational  competition
       .   increased strides in the production of synthetic leather
       .   higher per unit cost of production in some plants --
          especially the smaller size
       .   lower per unit profit
       .   difficulty in meeting (physically and financially) occupational
          safety requirements
       .   plants becoming physically worn out
       .   inadequate owner income
       .   present owner reaching retirement age

It is anticipated tanneries will continue to close in the future for the
same or at least similar reasons as those stated above.   This must be
considered when estimating plant closures attributed to  hazardous waste
management requirements.

As was discussed in Chapter II, Methodology, barring unusual circumstances,
most firms would cease  operations  if they could not adequately  absorb
required  costs.  The most obvious  measurement of a firm's ability to absorb
the costs is its ability to maintain a positive income after incurring
hazardous waste management expenditures.

If the situation arises where incomes are negative, some firms  will remain
in operation as long as they can cover their variable costs (positive cash
flows).   However, as they will eventually be required to meet their over-
head expenses, these firms cannot operate in this manner indefinitely.

The remaining situation that could arise is when firms maintain a positive
income and generate a net present value  (NPV) of their cash flows at their
cost of capital which are positive.  This indicates that these  firms are
earning a return on their operation which exceeds their cost of capital.
If their  NPV's are negative then the firms could liquidate, realizing salvage
value in  cash, and reinvest in a more financially viable investment (one
which would earn at least their cost of capital).

With the  above in mind, review of the model plants' impacts reveal that in
all situations, the models maintained positive profitability levels after
incurring the costs of hazardous waste management (Table 39).  Further-
more, review of Table 40 reveals that all tannery models maintained
positive  cash flows after meeting the proposed regulations.

Review of the models' net present values indicate that all models maintain
positive  net present values.  Thus for these tanneries with positive NPV's,
it can be expected that very few, if any, will close due to hazardous waste
management regulations.
                                    109

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Production Loss

As discussed in the previous section, of the estimated 230 leather tanneries
and finishers that potentially could produce hazardous waste, it is not
anticipated that any will cease operation solely because of regulations of
concern.  Accordingly, it is doubtful that the leather industry's total
production will be affected.  This is particularly true since, during the
last two years, total domestic leather produced increased by 18 percent
or 3.5 million cattlehide equivalents annually.  During this time, the
Tanners' Council of America reported additional closures.  Thus it appears
the industry does have the capability to absorb the volume lost by those
operations ceasing operations within a reasonable range.

                D.  Employment and Community Effects

The estimated number of employees in the Leather Tanning and Finishing
Industry is estimated to be 26,000 in 1976, up from 23,000 in 1975.  His-
torically, however, the number of employees has declined.  In 1967, employ-
ment was approximately 31,000.

As there are no projected plant closures attributable solely to hazardous
waste management, it is anticipated there will be no loss of employment
resulting from the imposition of the regulation.  Accordingly, it is
doubtful that communities will be affected either.

                    E.  Balance of Trade Effects

The impacts of hazardous waste management are expected to result in little
or no effect on the United States' balance of trade.  As discussed in pre-
vious sections, the Tanning Industry has historically been losing volume
to international competition.  However, the majority of these losses are
attributable to trade restrictions and agreements and not so much due to
lack of competitive prices.  Additionally, since domestic leather prices
are not expected to increase because of hazardous waste management, it is
doubtful that the competitiveness of the domestic tanners will be
affected and thus their ability to compete on the international market
will remain approximately the same.
                                     110

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                       IX.  LIMITS OF THE ANALYSIS
There is little published information regarding the structure, pricing
and economic data of the Leather Tanning and Finishing Industry.   Much
of the descriptive data used in this report were originally compiled by
the Tanners' Council of America for inclusion in the previous EPA reports
concerning the Leather Industry and, at the time, were considered to be the
most complete and accurate source available.  This information has been
updated for utilization in this report.  Also, information from an industry
data collection portfolio provided additional input for the report.  Never-
theless, much of the information required to develop this report still did
not exist in quantifiable form but was derived from personal discussions
with individuals knowledgeable of the industry.  This chapter discusses
the general accuracy of the report and some of the key assumptions in-
volved.
                           A.  General Accuracy


The data and other information used in this study were drawn from published
governmental reports, the industry trade association, an industry data
collection portfolio, and from extensive contacts with individual tanneries.
Information on the status of hazardous waste generation, recommended manage-
ment technologies and costs were furnished by EPA.  Every effort was made
to verify the data and other information used.

Detailed data on size distribution by types of plants are not available.
Using industry size distributions from the Census of Manufactures, together
with information obtained from the Tanners Council, the technical contractors
and contacts, segmentation of size and type of plants were made for each
industry.

Financial information concerned with investments, operating costs and
returns was not available for individual plants or firms.  As a result,
the financial aspects of the impact analysis were, of necessity, based
on synthesized costs and returns for "representative" types of model plants.
These costs and returns were developed from a variety of sources including
published research from universities and government agencies, information
obtained from the data collection portfolio and published financial per-
formance data.

Throughout the study, an effort was made to evaluate the data and other
information used and to update these materials wherever possible.  Checks
were made with informed sources in both industry, government and universities
to help ensure that data and information used were as reliable and as repre-
sentative as possible.  For example, construction costs, working capital
requirements, proportions of capital financed through debt and equity and
profitability ratios were checked with the appropriate persons in industry
firms who are experienced and knowledgeable in these matters.  Efforts were
made to use the latest data available.
                                    Ill

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Specifications of the contract require the Contractor to use waste manage-
ment costs provided by EPA.   The Office of Solid Waste Hazardous Waste
Division, EPA, through its technical  contractors, provided recommended
alternative disposal systems and annual operating costs which were adapted
to the types and sizes of "representative" model plants used in this analysis,
The recommended alternative  primarily consisted of disposal  in secure land-
fills, Pathway  Level III technology.  Level  of waste generation by plant
type was taken from the EPA  Assessment study and checked to  the extent
possible by the Contractor.

Given the accuracy of the costs for disposal  in secure landfills, it is
believed that the analysis represents a usefully accurate evaluton of the
economic impact of the proposed pretreatment guidelines.


                            B.  Range of Error


Different data series and different sections of the analysis will have
different possible ranges of error.

Errors in Data - Estimated data error ranges as an average for the industry
are as follows:

                                                          Error Range
                                                           (Percent)

       1.  Information regarding the organization and
           structure of the  industry, number, location
           and size of plants, and.other information
           descriptive of industry segments                  +_ 10

       2.  Price information for products and raw
           materials                 :                        +.15

       3.  Cost information  for plant investments and
           operating costs                 ,             •  •   +_ 15

       4.  Financial information concerning the industry     +_ 10

       5.  Hazardous waste management costs                  +_ 30 to 40
                                 112

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                         C.   Critical  Assumptions


In an economic impact analysis of most any industry, it is inevitable
that simplifying assumptions must be made to bring the problem into a
framework of analysis consistent with the constraints of time, budget
and data availability.  The  major critical assumptions used in this
analysis are as follows:

      1.  Types and sizes of the model plants are representative of plants
          actually existing  in the industry and of plants expected to be
          built in the future.

      2.  It is assumed the  financial  data are representative of costs
          and returns of existing plants or new plants to be constructed
          after promulgation of proposed regulations.  As stated earlier,
          the model plant financial data are on a constant 1975 dollar
          basis and can be adjusted at future times to reflect the future
          economic activity.

      3.  Levels of profitability reflected in model plant profiles (based
          primarily on the average of the period from 1970 to 1975 so as
          to include years of high and low profits) will be the same in the
          future.

      4.  It was assumed that the economic impacts of hazardous waste manage-
          ment on those products not included in the detailed analysis of
          "representative" plants could be evaluated in general terms
          through associating them with those "representative"model plants
          for which detailed analyses were made.  This association was based
          primarily on the fact that models were developed for a single
          product plant which represented a majority of industry segment's
          production.  In most cases, there were actual plants producing
          products in similar combinations to the model plants which was
          the primary objective where possible.

      5.  Hazardous waste management costs and waste stream characteristic
          estimates were supplied by the Office of Solid Waste, Hazardous
          Waste Division, EPA.  It is assumed that these data are realistic
          in terms of:

          (a)  Applicability of disposal technology recommended.
          (b)  Annual operating costs for the technology.
                                    113

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                          Selected References
 1.  Baker, Allen J., "Hides and Skins," Livestock Marketing:'.Situation,
           Economic Research Service,  USDA,  Washington,  D.  Ci,  November,
           1971.

 2.  National Commission on Water Quality,  Economic Impact  of Water
           Pollution Controls on Selected Food Industries,  The  Leather
           Tanning Industry, November, 1975.

 3.  New England Tanners Club, "Leather Facts," Peabody, Mass., 1972.

 4.  Poats,Fred, "Cattle Hides and Shoe Prices." Marketing  and  Transpor-
           tation Situation, Marketing Economic Division, USDA, Washington,
           D.C., August, 1972.   '

 5.  Poats, Frederick J. and Thompson, John  W., "Alternative  Markets  for
           Cattle Hide Trim," Marketing Economics Division, Economic
           Research Service, USDA,  Washington, D. C.,  February, 1965.

 6.  Robert Morris Associates, Annual  Statement Studies, 1973-1977.

 7.  Tanners' Council of America, "Membership Bulletin Leather  Industry
           Statistics, 1955-1976,"  Trade Survey Bureau,  Tanners'  Council
           of America, Inc., New York, N.Y., 1977

 8.  Thompson, John W., "Marketing Spreads  for Leather Products," Marketing
           and Transportation Situation, Marketing Economic Division,
           Economic Research Service,  USDA,  Washington,  D.  C.,  February,  1965.

 9.  Thompson, John W., and Poats,  Frederick J., "Economics of  Segmenting
           Cattle Hides," Marketing Economics Division,  Economic Research
           Service, USDA, Washington,  D. C., 1965.

10.  Troy, Leo, Almanac of Business and Industrial Financial  Ratios,  1976.

11.  United Nations/Industrial Development  Organization  Vienna, "Marketing
           and Export Possibilities for Leather and Leather Products  Manu-
           factured in Developing Countries," United Nations, New York,
           New York, 1972.

12.  United Nations/CTAD, "The Kennedy Round Estimated Effects  on Tariff
           Barriers," United Nations,  New York, 1968.

13.  United Nations/CTAD, "Leather .and Leather Products," United Nations,
           New York, N.Y., 1971.

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