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NATIONAL RECOVERY ADMINISTRATION
CODE OF FAIR COMPETITION
RABBIT FUR DYEING
The Code for the Rabbit Fur Dyeing Industry
in its present form merely reflects the proposal of the above-mentioned
industry, and none of the provisions contained therein are
to be regarded as having received the approval of
the National Recovery Administration
as applying to this industry
WE DO OUR PART
GOVERNMENT PRINTING OFFICE
AS SUBMITTED ON AUGUST 24, 1933
REGISTRY No. 911 1-03
Digitized by the Internet Archive
in 2011 with funding from
University of Florida, George A. Smathers Libraries with support from LYRASIS and the Sloan Foundation
COD)E INDEX #911/1/03
To: Maj. Gen. C. C. Williams, National Recovery Admainistration~,
BRIEF OF NATIONAL ASSOCIATION OF RABBIT FUR DYERa, ETc.
The rabbit fur dyeing industry is made up of a number of concerns
engaged as service organizations in the bleaching anld/or dyeing of
rabbit skins (pelts), the work being performed for others on a, con-
tract basis. Although the volume of business is substantial, and the
number of persons employed in the industry sizeable, the services
are performed by a small number of organizations located in the
vicinity of New York City and the State of New Jersey.
The dyeing services rendered in connection with rabbit skins by
reason of the actual cheapness of the rabbit skin as compared with all
other furs, creates operating problems distinct and wholly different
from those existing in the industry engaged in dyeing higher priced
or so-called, "fancy furs. The requirements of this industry, its
labor and production problems as well as the general nature and
~conduct of its operations are to a great extent foreign to those of the
"fancy dyeing mldustry. W7e claima that we are an mzdustry separate
and apart from the general fur dyeing industry, particularly insofar
as our labor azid production problems are concerned, and that we are
entitled to a separate code. The industrial reasons for this contention
are set forth more fully hereinbelow.
THE ASSOCIATION--ITS ORIGIN AND PURPOSES
The association was recently organized for the sole purpose of aiding
the Government in carrying out the provisions of the act. The entire
rabbit dyeing industry is made up of a group of eleven concerns, ten
'of which specialize as service organizations in the dyeing of skins for
others on a contract basis, and one concern being engaged in dyeing
for its own account exclusively. This concern is engaged in fur
dealing, fur dressing and likewise as a fur dy~er. Of the ten concerns
who are exclusive service organizations, one concerns, namely, the
rGreat N~orther 1Fur Dyeing & D~ressing Co., Inc., has approximcately~
20% to 25%r of the total rabbit- dyeing business. Teblneo
75% to 80%J is divided among the remalining concerns. This per-
centager vriespg dpendingl n upon the color of the skin which is in vogue.
Freqluent~ly, w-ith ~the change in styles, the percentage of this one
concern is considerably decreased.
RABBIT ]FUR DYEING INDUSTRY
T~he industry in. the past few years, similar to many others, has
suffered not only9 from general business conditions, but from matn-
mrJade practices which have stifled fair competition in the industry
and brought about chaotic conditions. By this wve m~ean that by
reason of cut-throat tactics, price slashing below cost of production,
secret rebates not passed on to thze consumer, but granted for the
purpose of ruining fair competition, and other similar practices, those
engaged in the industry have found it difficult to operate in such a
manner so as to permt the payment to labor of a reasonable and
fair rate of wage, and still permit some return on capital investment.
It is our hope that under the guidance and with the support of the
Administrattion coupled with the powers granted to it, by t~he Act,
we may be able to rehabilitate the industry, and not only give more
emnploymrrent, but give better employment in the sense of wages and
hours, arnd generally aid in national recovery.
WIith this purpose mn mind, all of the eleven organizations engaged
in the bleaching and/or dyeing of rabbit skins wvere gathered together
in order to form a representattive association, and formulate a code.
Each of the eleven concerns were represented. A code was drafted
and submitted for their consideration. It was suggested, that in.
order to effectively carr out the provisions of the code and in order
to assist the Administration inl its desire that all industries be self-
governmng in this great enterprise, that an association be organized
which would be the medium through which this industry could deal
withn the government and whose purpose it would be to aid in the
enforcement of the code and suggest practical and necessary changes
of benefit to the industry. This association was thereupon organized.
Of the eleven concerns present, the one concern engaged in dyeing for
itself has been temporarily excluded from. consideration as a member,
for the reason that this concern. is undecided as to whether it should
become a member of this association made up of service organiza-
tionzs,. or whether it should become a member of a man ufacturers'
association. Of the remaining ten service organizations, mine became
members of this association. Their names and addresses are as
Iceland Fur Dyeilng Co., Inc., 11 HTope Street, Brooklyn, ~N.IY.
Grand Fur Dyeing Co., tInc., 1013 Grand Street, Brooklyn, N.Y.
Philip A. Singer & Bro., Inc., 16i9 Malvern Street, Newark, N.Jt.
Mendoza Fur DyTeing Works, Inc., 158 We~tst 29th St., New YJork
Diamond Fur Dyeing Co., Inc., 257 West 27th St., New York City.
Hudson Fur Dyeing, Inc., 29 Congress Street., Newark, N.J.
Oakland Fur Dyemng Co., Inc., 3278 Greene Street, Brooklyn, N.Y.
Nu~lest Fur DyJeing Co., Inc., 555 Parki Avenue, Brooklyn, N`.Y.
Van-Dye-Way Corporation, 148 West 28th Street,~ Newr York: City.
The Great Northiern~ Fur D~yeing &t Dressing Co., Inc., did not
become a mlember of the Association. Their representative stated
that this concern did not care to subscribe to our proposed code for
the reason, that in our code we set up a Board of Trustees and made
other provisions intended to aid in, thle enforcement of the code and
intended to assure~ its proper observance by all concerns, which forml
of supervision they did not approve of.
Thle estimated total numiiber of persons employed in the rabbit
dyeing industry amount to approximlately 1,800 to 2,000. Of this
number, approximately 400 are estimated to be employed by the
Great Northern Fur Dygeing & D~ressing Co., Inc. TPhe remaining
number of approximately 1,500 or 1,600 employees are employed by
concerns whzo are members of this association.
The proposed code which has heretofore been filed with the Admin-
istration. in behalf of this association has been approved entirely by
eight out of the nrine members of the association. The nonassenting
member, Van-Dye-W~ay Corporation, has approved of all of the terms
of the code, with the exception of the rate of wages. It has stated that
it desired to submit a separate schedule of wages to apply solely to its
concern for other reasons.
It is our belief, that because of the conditions existing in this
industry-, that our association is a necessary element in order to
properly assure the observance of the code. W~e feel that this associ-
ation, made up of small and large concerns representing the industry,
will serve manyy purposes in. aiding the Governmrent in the enforce-
me~nt of the code. All service organizations engaged in the rabbit
fur dyeing industry, with the exception of the Gre~at Northern Fiur
Dyeing & Dressing Co., Inc., have indicated their willingness to file
regular reports of labor employed and rate of wage paid with the
association, and to k~eep the association informed with respect to such
other maatters as may be required from time to time in, connection
with the enforcement of the code. The Great Northern Fur Dyeing
& Dressing Co., Inc., has indicated that it is not agreeable to filing
reports with the association of labor employed, hours and rate of wvage
paid. In keeping with the expressions of tfhe administration towards
self-policing and self-governmaent in industry, we submit that thze
best interests of the industry of labor elmploy-ed therein. and of the
Government can be accomplished through our trade association made
up of mlemnbers of the industry who are familiar .with the current
existing conditions, and who will be quick to recognize anly attempted
violation of any provisions of the codec.
(A) FURS DRESSED
There is no available accurate statistical record which applies par-
ticularly to the rabbit fur dyeing industry. TPhe only records wvhich
have, been obtained through, the Department of Commerce consist of
an analysis of establishments "engaged primarily in scraping, curry-
ing, bleaching, and dyeing pelts and in dressing hair." This analysis
would seemn to include not only rabbit fur dyers, but also all other fur
dyers (fancy furs) as wvell as concerns engaged in the dressing of
rabbit furs and of fancy furs.
The summnary for the years 1927, 1929, and 1931 above referred to
indicates the following:
Year err Wages
1927....... ....... ..... 5, 540 $10, 360, 987
1929_........_ _. ... ...... ____ 5, 167 8, 596, 377
1931........... ....~.~... ......... __ __ 5, 160[ 7, 968, 000
It should be noted that in the entire fur dressing and dyeing in-
dustry from. 1927 to 1929 the decrease in wage earners was slightly
over 6X'%~, and the decrease in wages over 17%0. From 1929 to
1931, there is practically no decrease in wage earners, and yet, there
is a further decrease inl wages of almost 8%0 over the same period.
(B) RABBIT INDUSTRY
We are able to furnish only estimated figures wvith respect to the
rabbit fur dyeing industry, in view of the fact thrat no statistical
reports are now available or have heretofore been furnished by con-
cerns engaged in this industry. With the authority~ of the Act,
after thae approval of thze code for th~e industry, we wil be inl a posi-
tion to demand and procure accurate statistical reports from all
concerns for the present time and for years past. Thie following
estimated figures are submitted:
Annual By non-
Persons employed (wage Year Skins processed produc- associa- B 0V,-
earners) tion mn tn mem- members
1,800 to 2,000................. 1933 18,000,000 to 20,000,000.......... $2, 000, 000 20-25 75-80
About 2,500.................. 1929 20,000,000 to 23,000,000.......... 2, 500, 000 .. .....
~Wage earnlers employed in 1933 estimateded: AssPociation, about
1,600, nonassociation, about 400.
(c) CHANGES IN INDUSTRY (GELLING PRICES)
That since 1929, although the reduction in production cost has
been between 10% to 15%J, the selling cost of the articles processed
in this industry have been reduced in some instances as much as
50%0. Sealine skinls which, were processed in. 1929 at a service charge
of from 14~ to 16e are nowv processed at a ser-vice charge of 8f to 10 .
Bleached and dyed rabbits wh13ich were processed in. 1929 at a service
charge of from 25e to 30~ are now processed at a serv-ice charge of 141C
to 16 D~yed whites which were processed in 1929 at a ser~vice~
charge of from 201 to 22~ are now processed at a services charge of 9~
to 12 ~. ]French beavers which weret processed in 19'29 at ae seric
charge of from 22~ to f25~ are~ now processed at a service charge of 121
to 15 .
That from 1929 to thle present time, there has been a reduction in
the? volume of skins processed inl the indu~stry) of approximantely 25%~,
with the resultingr~e~du~ctio n in pay rolls and labor emlployed.
The selling price of the skins processed hals been forced downwfard
in mosat cases by ruthless, unfair, and cut-throat competition in the
industry. It is natural to assumec that in order to carr outf a camp-
paignn of such. competition, the emnployer mnust place some of the
expense of his campaign onl thne shoulders of hris wage earners, who,
in the last analysis, suffer inr the rate of wagne paid to theml. Event u-
ally, this condition has effected other concerns who w~ere obliged to
meet the unfair colmpettitive tactics, andr wvho, in turn, had to seek
the reduction in their ovecrhead, writhl tlhe .resultant loss to labor in
reduction of wages.
This conditions has likewise held back capital investment, which
would ordinarily be required in additional prod-uctive machinery and
maintenance, and which in turn wYould have resulted in greater
It is our sincere belief, that with the elimination of some of the
practices now existing ini the industry, and the removal of competi-
tivet prices based upon the labor costs of producers and the superv~i-
sion, of all concerns afforded by thle Act, there will be considerable
increase. in business, and certainly a considerable increase in the num-
ber of persons employed as well as in the rate of wage paid to them.
LABOR BENEFITS OF CODE
1. Rate of Wage:
The minimum rate of wage proposed in our code will result in an
increase of appropriately 35%j of the present minimum rate. At
the present time, male help is being employed in the industry- at a
minimum rate as low as 32~ an hour, the greater average being about
40~ per hour. The rate fixed ini thae proposed code of 501 per hour is
a decided improvement.
At the present time, female help is being employ-ed at a minimum~
rate as low as 20& an hour, the greater average being about 28k per
hour. The increase to 351 per hour is a decided improvement.
2. Maximum Hours:
TChe maximum. number of hours provided for in the code is likewise
of considerable benefit to labor. In seasonal times it has been custom-
ary in this industry to employ wage earners, particularly male help,
for time and overtime, amounting in some cases as high as 13 or 14
hours a. day. At the present time, the average number of hours of
male help is between 44 and 48 hours a week not including overtime.
The reduction of hours specified in the code to a 40-hour week non-
seasonal, and 46-htour week seasonal, plus the limitation of overtime to
a total of only 120 hours during the entire year, will necessitate the
employment of a considerable number of additional male help. We
estimate that the limitation on, the maxiumn hours fied in the code
will result in an increase in employment during peak periods of ap-
proximately 20%0, and an increase during nonseasonal periods of
slightly less than this percentage.
Applying the~ maxim~um-hour provision of the code as effecting fe-
males, wve estimate that the provisions of the code will require an in-
crease of at least 10% in the employment of female help.
SEASONAL AND OVERTIME EMPLOYMENT
In this industry, seasonal emnploym~ent is a necessary evil. T'he
particular requirements of the industry are such, that concerns
engaged in the marketing of our products, namely, our customers, are
unable to determine even a month ahead the kind of colors or styles
which wjll, be desirable. Accordingly, no merchandise is sent to the
dyers for processing for long periods in advance. In fact, it is cus-
tomary for merchandise to be sent to the dyers by our customers
practically at the last moment when they have orders for the resale of
the skins. It, therefore, follows that m seasonal times, the dyers
will have a rush of work which must be processed and delivered within
a week or tw'o. TLhis necessitates double shifts and overtime on the
part of the employees. We ha~ve reduced the number of overtime
hours considerably by the maximum provisions of the Code. WPe
believe, that to reduce it any further, would create a great hardship.
In the! processing of rabbit skins, the dyeing process itself requires a
period of from three to four days. Immedliatecly a~fterT t1he? dye1ing
there is an additional process which requires about tw~o or three days,
and which consists of the drying and a careful cleaning of the skin.
Once the dyeing process on the skin is commenced, it is essential that
the full process of dyeing, drying, and cleaning be completed, without
a~ny interruption. In fact, a delay of a few hours in commencing the
:drying and cleaning process, after the dyeing opera tion, is v~ery often
iinjurious to the skin, and wvill render it unmarketable. For this reason
dur~iang seasonal periods particularly overtime work is absolutely
-necessary in order that the process, once commnenced, la~y be com-
pleted. Accordinlgly, it is submitted, that limcitationr of overtime to
120 hours, spread over the period of a year, is necessary for the
industry in addition to the maximum hours provided for seasonal
periods. This overtime is actually in the sense of emer~gency time,
without which the industry would suffer great injury.
DISTINCTIONS BETWEEN RABBIT DYEING INDUSTRY AND FANCY D'YEING
Trhe rabbit industry is now recognized as an industryT dealing with
the type of fur skin which for practical purposes has become a nreces-
sity with the middle class of purchasing public, which are in the
majority. The rabbit skin, by~ various processes and treatments, is
made serviceable, economical, and of a price where it can compete
successfully with the average-priced cloth coat, still giving the wvearer
th2e added service and benefit. of warmth, durability, and style.
The distinguishing features of the dyed rabbit skin is that the! cost
of the process applied to the dressed skin is very great in proportion
to the value of the skin itself. The service charge on t~he, rabbit skin
is a substantial item of the cost as will be seen from the figures herein-
belowc set forth. On the other hand, with, respect to all other fur
~skins which are dyed, the service charge is usually a very mlinor part
of the cost. of the article. Fo xmltevleo h vrg abit
skin which comes to the dy-er in a dressed st~at~e is in the neighborhood
of 20~ to 25~ (ths includes a dressing charge of approximately 71t per
skin). The service charge in connection wvith. thie dyeing of t~he skin
is now in the neighborhood of 8g to 18 dependent upon the finished
It therefore appears that the dyeinga service charge in some cases
is as highly as 70%0 of the cost of the dressed sklin. It is ev-ident. that
service c~ha~rge for dyei~ng of rabbit skins is almost as grat as the
initial cost of the raw skin itself.
COmIpar'ing thne servic-e charge~ on:r~abbits with the service charge
for dyeingc of other skcins, we submit, the follow~\ing: So-called '"fancy "
ifu skis which are dyed, run in values froml as lowF as $1.00 per sk~in
to as high nas $fl.1750 per skin. The labor co-st in, dlyeingr these skiins
is really an insignificantlt item in takiing thc elt~ir~e (ast. Inl roost cases
the cost of dying~ t he tskinis is in thle necighbl~orhoo, I d of .12 to 10%~i of
the tot al cost o1f the arti('le, fo~r examplel~, w.olf skinsd whlichl Cost inl the
neighborhood of $8.00 to $10.00 a skin involve a dyeing charge of
$1.00 or less; whte foxres which are worth. from $35.00 to $40.00 a skin
required a service charge of about $2.00; squirels which are worth from
50g to 60$ a ski require a service charge of about 10 ~; weasels which
are worth from $2.00 to $3.00 a skin require a service charge of about
Because of the difference in the service charge in the dyeing services
ordered by our industry anld the fancy fur dyers, the two industries
have at all times been considered distinct anld separate, particularly
in. their labor problems. The fancy fur dyers always paid a higher
rate of wag~e than that customarily paid by us, for two reasons. The
-first is the, fact that in the fancy--dy-eing industry, the labor required
:is of a more skilled nature; more hand work is required; the article is
:a more -expensive skrin, requiring ~careful handling and treatment. Thte
rabbit skiin requires less skiilled labor due to the fact that more machin-
ery is employed, and the skin is so much cheaper. Thre second reason
for the differential in wages is, that where a higher price skin is in-
-volved, a difference of a fewi cents an hour inz the labor charge can
easily be absorbed in the price of the article.
Furthermore, this industry must compete with the importation of
dressed and dyed rabbit skins from~ Fratnce, Germany, and Belgium.
At the present time, it can fairly compete with the foreign markets
for the reason that the service charge for dyeing and dressing in this
country, plus the cost of the skin1, is about the same or slightly less
th~an the cost of importing the rabbit skin inlclusiv-e of the duty. An
increase in the labo0r cost, in excess of the amount suggested in. the
proposed code filed by us, would give to the import market an unfair
:advantage over the domestic product by reason of the higher cost of
thle domestic article. Such an increase would benefit the foreign
markets to the exclusion and detrimcent of the domestic industry. All
benefits to labor contemplated by the code would be lost in such event,
due to the reduction or decrease in production which would necessarily
follows, unless the tariff duties on the imported skins would be pro-
The rabbit skin cannot absorb any greater increase in labor cost
than that provided for in our proposed code. This conclusion. has
been arrived at after careful consideration and discussion, wnhichwas
engaged in by representatives of all concerns inv9olv-ed in this industry.
Anty greater increase would be prohibitive, and would only result in
idecreasedl consumption which would result in decreased employment.
I~n addition to thze labor difference above set fortha, the rabbit-
dyeingr industry requires a greater overhead for plant, machinery, and
dyestuffs. In treating the rabbit skins, machinery is required for
processes which are unnecessary to thze fancy fur dyeing industry.
F~or instance, some of the processes used which are foreign to the other
industry are sheering, unhairing, and brushing, in addition to the
usual dyeing and cleaning processes which are used by both industries.
'Special machinery and equipment is required in the rabbit industry,
in order that thie ski may receive the various treatments referred to.
"The rabbit dyers, because of thie necessity of additional maachinery,
hzave an increased overhead usually requiring three times as much
space for the same volume of gross business as that of the fancy dyers.
here is likewise the consideration of additional power, electric cur-
rent, m~echanicatl labor, repairs, machine maintenance, and capital
investment which aire not involved in the operation of th~e fancy
For all of these reasons, this industry has always been recognized as
unlique and distinct from that of the fancyg dyers. The products of
this industry are handled by different dealers, and these products have
We therefore submit that the proposed code heretofore filed byv us on
behalf of the rabbit fur-dyeing industry be considered and a~dopted-
separate and apart from anyT other fur-dyeing code.
In conclusion may we state that in submitting the proposed code for
the rabbit-dyeing industry, we have endeavored to include provisions
which wrill be of mutual benefit to those employed in, the industry, as
well as to the individual concerns engaged therein. It is our earnest
desire to lend our aid and cooperation in the national attempt to
rehabilitate all industries, and to encourage reem~ployment. We
pledge our support to the President and to the .Adrminst~ration in the
enforcement of the Act.
Dated New YIork, August 15, 1933.
NATIONAL, ASSOCIATION OFP RABBIT E\UR DYERS, INC.,
By MEYER GELLEN, SecrtarGy.
UNIVERSITY OF FLORIDA
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