We have now reached the point where we cannot even consider continuing our shutter engineering departments and experimental departments, for to do so, and to keep the interest of our engineering personnel, we would have to maintain a reasonable shutter manufacturing schedule. Another fact which will illustrate the gravity of the situation is that there are only two shutter manufacturers in the United States. During the last World War, we were sole supplier for many intricate and precision optical and photographic instruments, and to maintain these very critical skills for possible future use in the event of a national emergency, we must have the protection of higher tariffs on photographic shutters. There are only two shutter manufacturers in Germany, and their volume approximates 1 million shutters per year. Our production has been reduced to 20,000 from a high in recent years of 140,000. The German manufacturers do not need the protection of low tariffs, in fact they could compete and undersell the United States camera manufacturers if the tariffs were 50 percent or higher. We have not only reached, but gravely surpassed, the so-called peril point, and without assistance in obtaining higher tariffs on photographic shutters, we will have lost all of our photographic shutter business that we have enjoyed for over 56 years.

We, in this country take pride in having created for our people the highest standard of living in the world, and now it is certainly our job to maintain this high standard of living, however, to do so, we must continue to pay good wages. But, we cannot continue to pay good wages, and at the same time permit imports from countries which have much lower wage scales and standard of living, for to do so, would most certainly result in causing a decrease in our own standard of living, and imperil our national security.

We are enclosing a copy of our answers to Representative H. C. Ostertag's survey entitled "Questionnaire on Foreign Trade and Rochester Metropolitan Area" which we believe will be of assistance to you. Also enclosed are two prints, one showing an exploded view of our Rapax shutters, and the other showing a picture of our shutter, less the cover or nameplate, which will give you an idea of the intricacy of the photographic shutter.

We were not informed by the United States Tariff Commission as to the reasons for their actions in denying our application; however, it is our opinion that one of the reasons for their denial in both instances was the fact that, even though some relief could have been accorded us under section 336 for photographic shutters which were covered under section 1551 of the Tariff Act of 1930, this relief would have been entirely without effect due to the fact that photographic shutters imported into this country where the lens is of chief value would be dutiable under section 228B under the Tariff Act of 1930; and, since the rate of duty applicable to section 228B had already been decreased under a previous trade agreement, section 336 of the Tariff Act would have had no effect on this situation unless combined with an application under section VII of the Trade Agreement Act of 1951. To the best of our knowledge, there is no provision in the rules of practice of the United States Tariff Commission for the making of a dual application. If a dual application were accepted, it would appear to be extremely difficult to implement any decision granting relief resulting from such an application.

Very truly yours,

WOLLENSAK OPTICAL CO.,

ROBERT E. SPRINGER, Treasurer.

83979-56-pt. 3—31

QUESTIONNAIRE ON FOREIGN TRADE AND THE ROCHESTER METROPOLITAN AREA A survey conducted by the Legislative Reference Service of the Library of Congress at the request of Representative Harold C. Ostertag

1. Name and address of our company: Wollensak Optical Co., 850 Hudson Avenue, Rochester, N. Y.

2. What are the principal products produced by our company?

1. Photographic shutters

2. Lenses for moving-picture cameras.

3. Projection lenses.

4. Government fire-control instruments, etc.

5. Scopes and binoculars.

6. High-speed camera and accessories.

3. What was annual output of these products in 1953 and 1954 in value and units of quantity?

4. With which products do you regard imports as competitive? Which imports?

Primarily photographic shutters, and as you will note from No. 3 above, imports have seriously affected our business.

5. To what extent, if any, do imports specifically affect your business?

The importation of photographic shutters has caused the 75 percent decrease in our shutter production as is illustrated in No. 3 above, and caused us to lay off a majority of our skilled shutter markers since we cannot compete with $0.15 to $0.50 per hour labor which exists in the countries from which shutters are imported. The labor content in manufacturing shutters is 85 percent of the unit cost per shutter, and at our average rate of $2.25 per hour we cannot compete with imports.

6. Do you sell products for export abroad? Give value and units of quantity for 1953.

Negligible. Value, 1953, $50,617.40; 1954, $41,884.42.

7. What percentage of your total business volume represents export trade? Negligible.

8. Are any materials used by you imported from abroad? If you do not have this information, will you please furnish a list of material that go into your products?

Imported materials: Raw glass, 1953, $3,000; 1954, $2,000.

9. What is your total average employment?

Approximately 825 in 1954.

10. What percentage of your work force is engaged in export business? Import business?

Negligible.

11. Shall appreciate any comment you may care to make regarding the significance of (a) exports and (b) imports to

(1) Our company: Export has never been an important factor in our business, due to low level of labor rates in competitive industries in Germany and Japan.

Imports of competitive products from abroad are, however, a most important factor in our business. Our company is rather unique in the optical and photographic industries in that we are specialists in the manufacture of shutters and photographic lenses. Practically all manufacturers of cameras, with the exception of Eastman Kodak who produce their own, purchased our shutters and lenses. This business, particularly the shutter business, has almost completely gone to Germany and we have been forced to lay off a considerable number of experienced personnel. Shutters are highly complicated precision instruments, more difficult to manufacture than watches, due to the variety of speeds and openings used in an expensive shutter. In October 1953 our shutter assembly departments had 110 employees; a year later they had 34 and further cuts are expected. Many of our shutter parts are made on punch presses. In October 1953 we had 14 press operators, a year later we had 2; we now employ 1. Many other departments are affected similarly. Our total employment of production workers in 1953 was 1,041; today we have 640.

Our shutter makers are highly skilled people with many years of experience. It takes 2 to 3 years to train one and only a small percentage of people, to whom we give training, succeed in becoming shutter makers. Shutters are not items that can be mass produced. Each is built individually. Our Rapax shutter has 186 parts, many of them so small that they must be handled with pincers. We are losing these skilled people, dut to layoffs. Our union contract and seniority rules give us only slight chances to keep them. We have no assurance that we will ever get them back. The same is true of other skilled occupations. Precision lens polishers and lens grinders were listed by the United States Department of Labor as extremely scarce and were deferred by draft boards during World War II and the Korean incident, yet we have to let these skilled people go for lack of work, perhaps forever.

To sum it all up, the impact of imports on our company is disastrous. Naturally, we are considering steps to keep this company in business, but we do not see any way of keeping our skilled help on our payroll.

(2) On the industry: As mentioned above, our company is rather unique in the industry in the particular combination of special services we supply, but all of the optical and photographic industry is affected to some extent. Some of the manufacturers in the industry produce large amounts of photographic paper, film, and chemicals. To them, precision optical instruments and lenses are a sideline, sometimes not even a profitable one. As far as those companies are concerned, their survival is not at stake, but the skill of the employees involved in work similar to ours is at stake. Other manufacturers in the field produce cameras.