VII. Economic Factors for Consideration that May Weigh Against Minimum Wage Increases

Slow U.S. Market Growth

Production of tuna rose 47 percent worldwide between 1991 and 1997, with the greatest increases coming from producers in the Africa/Indian Oceans, Latin America, and Southeast Asia. These increases reflected shipments into heavy growth areas of consumption in Latin America and Europe.65

The robust growth of canned tuna consumption in certain parts of the world contrasts with a much slower growth in the U.S. Meanwhile, foreign competition has increased for the U.S. market. Slow market growth and increased competition puts great pressure on producers in American Samoa to minimize costs.

The largest production sector, Southeast Asia, including Thailand, the Philippines, Indonesia and other members of the Association of Southeast Asian Nations (ASEAN) comprised 29.1 percent of worldwide canned tuna production in 1997, with Thailand alone accounting for 19.6 percent. Low labor costs were a factor in Southeast Asia's growth. However, other major causes of the shift in production from the eastern Pacific to the western Pacific fishing waters included the much greater supply of tuna there, and the fact that dolphins do not run with tuna in those waters, allowing fisheries to catch tuna without harming dolphins.

While Thailand markets canned tuna to other countries besides the U.S. (e.g., Japan), American Samoa's production is only for the U.S. market, given that market's advantages for a U.S. territory (e.g., no tariff, compared to a 24 percent tariff that would have to be paid on exports to Europe). But the canned tuna market in the U.S. has matured, averaging only a little over one percent increase in sales in the last 15 years, compared to an average 2.5 percent gain worldwide. Competition by fast food restaurants, the decrease in can size from 6.5 to 6.0 ounces, and some perception of lower quality due to a shift in tuna species being canned, may also have helped slow the U.S. market's growth.

While U.S. tuna supply experienced declines and advances from 1992-2001, the annual per capita consumption of canned tuna remained fairly flat during this period. From a low of 2.8 pounds per person in 1982, canned tuna consumption increased to 3.5 pounds in 1992.66 After minor fluctuations, per capita consumption again totaled 3.4 pounds in 2003. However, per capita consumption in 2001 was only 2.9 pounds—by far the lowest level in almost 20 years. This reduction appears to be partially the result of the substitution of other fish products (fresh or processed) for canned tuna products. For example, in 2001 annual U.S. shrimp consumption per person (3.4 pounds) exceeded canned tuna consumption for the first time. Despite tuna consumption rising to 3.4 pounds in 2003, the consumption of shrimp had a record year of 4.0 pounds per person.

As a relatively undifferentiated commodity, canned tuna is often met with widespread consumer indifference to its country of origin or brand name. Price is often the key factor. Private label market product from Southeast Asian producers set the market price. Advertising is seen as essential for higher sales growth, so securing advertising with grocery chains is critical. But grocers will only advertise if the product is a loss leader, a low-cost item that brings in customers. Some experts believe there is great potential in the premium end of the market such as albacore tuna (produced mainly by Bumble Bee) and for value-added products such as snack packs, pouched tuna and tuna salads.

At the Sixth INFOFISH World Tuna Trade Conference, May 25-27, 2000 in Bangkok Thailand, the President and CEO of Bumble Bee Seafood, Christopher D. Lischewski, noted that in 1999 the U.S. market for canned tuna grew by 2.3 percent, almost twice the 1985-99 growth rate of 1.2 percent. Also on the positive side, he noted that, in terms of dollar volume per foot of shelf space, canned tuna remained third highest, after granulated sugar and regular coffee.67 On the negative side for tuna processors, he found that of all canned tuna sold in the U.S., 54.5 percent is sold with some sort of promotion, with average price discounting of "a staggering 31 percent," which may mean a loss for the retailer, but "given the traffic that the sale of tuna generates [e.g., bread, lettuce, tomatoes, mayonnaise], is still a profitable decision."

Discussing the low long-term growth in U.S. canned tuna sales, the Bumble Bee CEO said…

"The fault for this poor performance falls squarely on the shoulders of the tuna industry. Rather than focus on innovation and growth, the three major brands have fought an 'unwinnable' war to steal shares from one another in a flat to declining category. Nowhere is this more evident than in profit margins…Our results estimate that compared to 1980-84, profit margins have eroded by approximately US $6.75 per case. Multiplying this loss by the 35 million case retail market represents an annual profit loss of more than $200 million to the tuna industry."

Over the same period, he noted that retail prices had dropped in real terms, from US $43.19 per case of Chunk Light half-pound cans (1999 dollars) in 1980 to US $20.35 in 1999, a 53 percent decline in constant dollars.68

Chicken of the Sea presented to the Industry Committee 25 arguments that current conditions of the workplace, productivity and U.S. demand for tuna does not increase the profit enough to absorb increases in the minimum wage. Chicken of the Sea showed that from 2001 to 2003, average hourly wage increased by 2.5%, but that employment decreased by 2.6%.69 In addition, Chicken of the Sea argues that decreases in consumer demand and retail price along with increases in the foreign market imports have deteriorate the tuna cannery industry such that any increase in productivity is matched by a increase in the minimum wage.

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Foreign Competition

Labor rates for the largest exporters of canned tuna were recently estimated at US $0.66 per hour in Thailand, US $0.67 per hour in the Philippines, and US $0.77 per hour in Ecuador.70 The Philippines has a $5.00 per day average wage for Manila tuna workers, and lower wages in the provinces.

This partly accounts for the lower prices that are paid for imports by retailers who utilize private labels. This also provides an incentive for tuna canners to move production facilities to countries with low average wages in order to regain cost advantages. Unlike their foreign counterparts, the American Samoa canneries are sold exclusively to the U.S. market. Foreign companies have the ability to sell their products to other markets, giving them a competitive advantage.

The data below (Table VII A) show the value per pound of canned tuna imports versus that produced in the U.S. or U.S. territories (California, Puerto Rico and American Samoa).71 The market value of imported canned tuna as a percent of U.S.-produced canned tuna dropped from about 81 percent in 1997 and 83 percent in 1998 to 71 percent in 1999 and 65 percent in 2000. The value of these data are limited, since the import value is the market value in the foreign country and does not include import duties, shipping freight charges and insurance, and the U.S. product value does not contain inland freight charges and insurance costs to the buyer. Therefore, for any given year, the ratio of the imported versus domestic wholesale price is very difficult to determine.

However, the data do clearly show that the price paid by the importer dropped sharply in 1999 and 2000 compared to the wholesale price paid for domestically produced canned tuna. It helps to explain the sharp increase in market share of imported canned tuna seen in 1999.

After the U.S. quota is filled, Thai exporters claim they have to lower their price 6.5 percent because their buyers will not absorb any of the duty increase (from six percent below the quota to 12.5 percent above it). As a result, the Thai industry buys up frozen tuna during the last quarter of the year, in order to prepare for orders to be entered in the U.S. early the next year, and thus takes advantage of the below-quota tariff rate. This causes short-term fish prices to increase, which some claim significantly raises production costs. The greater than normal supplies of tuna caught in 1999-2000, along with such early stockpiling, drove down the price of tuna to record lows, as noted earlier. In August 2000, Thai Union reported that second quarter profits fell 47 percent, as price fell 40 percent from the first quarter.72 Its relatively robust profit margin narrowed to 14.7 percent from 17 percent. No separate data were obtained for StarKist or Chicken of the Sea.

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Imports of Canned Tuna

The U.S. and the European Community (EC) together import about 80 percent of traded tuna, in roughly equal shares. The EC tariff is 24 percent on canned tuna. (Some countries pay no tariffs on tuna to the EC or pay a reduced rate.)73 The U.S. tariffs are six percent to 12.5 percent (35 percent on tuna packed in oil). The main suppliers to the U.S. in 2002 were Thailand, Ecuador, the Philippines, and Indonesia (in order of decreasing dollar value).

After a record high of 351 million pounds in 1991, imports of canned tuna into the United States decreased to 193.0 million pounds by 1996 (see Figure 22 Table in Appendix C). From 1996 to 1999, imports—mainly from Thailand—increased sharply, to 334.6 million pounds. Then, imports overall declined in the year 2000 by about six percent. Imports again declined in 2001, but by a smaller percent than the decline in U.S. pack, but have risen sharply in both 2002 and 2003.

Dolphin-Safe Standard

In December 2002, the Assistant Administrator for Fisheries in the National Oceanic and Atmospheric Administration (NOAA) of the U.S. Department of Commerce found that the intentional encirclement of dolphins by purse-seine vessels does not have a significant adverse impact on dolphin numbers in the Eastern Tropical Pacific (ETP). This finding changes the dolphin-safe labeling standard as it applies to purse-seine vessels operating in the ETP with carrying capacity in excess of 400 short tons. Previously dolphin-safe meant that no intentional encircling of, or setting nets on, dolphins occurred while tuna were harvested. The new standard allows tuna caught by large purse-seiners to be labeled dolphin-safe if no dolphins were seriously injured or killed during the set where dolphins were intentionally encircled or chased. The international implications for canned tuna production are potentially significant.

In response to a complaint challenging the final finding, the United States District Court for the Northern District of California issued an order that stayed the final finding’s implementation on January 21, 2003.74 That stay, effective for 90 days, means subsection (h)(2) of the Dolphin Protection Consumer Information Act again governs the dolphin-safe labeling standard. Consequently, tuna harvested in the ETP by purse-seine vessels with capacity of 400 short tons or greater cannot be labeled dolphin-safe if dolphins were intentionally encircled or netted.

On August 9, 2004 the U.S. District Court for the Northern District of California rejected the Department of Commerce’s efforts to change the “dolphin-safe” tuna labeling program. The judge ruled that the evidence that dolphins were not affected by being caught with the tuna and released had little scientific merit.75

Historically, dolphins in the ETP have been observed to swim above schools of tuna. As a result, crews on large purse-seiners would target and encircle the dolphins in an effort to capture the tuna below them. This practice often resulted in high dolphin mortality rates despite having specialty nets designed to retain the tuna while releasing the dolphins back to sea76. Dolphin-safe labeling practices that began in the early 1990s were partially responsible for canneries moving from the ETP to Western Tropical Pacific waters.

Because Mexico has received an “affirmative finding” from the National Marine Fisheries Service, it can encircle dolphins while harvesting tuna in the ETP with large purse-seiners and export this tuna as “dolphin-safe” into the United States if the NOAA Assistant Administrator’s final finding is upheld. As a member of NAFTA, Mexico has dutiable rates on canned tuna not in oil of 2.4 percent below the quota and five percent above the quota. These rates are being phased out altogether pursuant to NAFTA and will be zero in 2008. Given its location, the United States represents an attractive market for Mexican produced tuna.

Andean Trade Preferences Act

The Andean Trade Preference Act (ATPA) allowed for duty-free entry into the United States of various goods produced in Bolivia, Colombia, Ecuador, and Peru. A goal of ATPA was wider access to U.S. markets for Andean producers to facilitate development of economic alternatives to drug crop production.77 However, tuna was not one of the products granted duty-free status.

Recently the U.S. Congress considered legislation that would exempt Andean tuna from at least a portion of the tariffs imposed by the United States. According to Congressman Faleomavaega of American Samoa, StarKist lobbied Congress in favor of the proposed legislation while Chicken of the Sea opposed it.78 StarKist maintains tuna production in Ecuador (as does Bumble Bee) and would gain economically from increased access to U.S. markets. Chicken of the Sea does not process tuna in Ecuador and tariff exemptions for ATPA tuna could adversely impact its operations in American Samoa and/or Asia.

In July of 2002, Congressman Faleomavaega announced that the U.S. House passed Andean trade legislation that prevented canned tuna processed in Ecuador from entering the U.S. duty-free.79 However, the legislation did grant the President authority to allow tuna packed in foil pouches duty-free status. The U.S. Senate later that year passed legislation with the same revisions on tuna recommended by the House.80

Foreign nations will continue to press for U.S. trade concessions (i.e., an opening of U.S. markets) as a means to accelerate their domestic economic development. One incentive for the United States to consider these concessions is efforts by foreign governments to help curb or eliminate illicit drug production and importations to the United States.

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Tariff Rates

Shipments of canned tuna or other products from American Samoa into the United States are not subject to tariff rates as prescribed by the Harmonized Tariff Schedule of the United States. This is because American Samoa as a territory of the U.S. and is not considered to be an exporter. While foreign exporters pay no duty on all fresh, chilled, or frozen whole-fish tuna imports to the U.S., and pay a relatively low tariff rate on tuna loins (0.5 cents per pound), canned tuna imports are subject to more significant tariff duties.

The tariff rate for canned tuna, not in oil, in airtight containers, weighing not over seven kilograms, is six percent of value (ad valorem). The rate for tuna, not in oil, in airtight containers, weighing over seven kilograms, or weighing not over seven kilograms, but above the quota, is 12.5 percent. The effectiveness of quotas on canned tuna is explained in the next section.

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Quota on Canned Tuna Relatively Ineffective

A tariff-rate quota provides for an increased tariff when a certain quantity of imports is reached. A global tariff-rate quota applies to imports of canned tuna, not in oil, in airtight containers, which weigh, with their contents, not over seven kilograms. It applies to both light meat and albacore. The quota is set each year and is 20 percent of the canned tuna packed in the United States (excluding the pack in American Samoa) during the preceding calendar year. Any canned tuna in these designated categories (not in oil, not over seven kilograms) that is imported in excess of the quota is placed in the tariff category of tuna, not in oil, but weighing over seven kilograms, and is dutiable at that category's rate of 12.5 percent.

The quota thus does not set a limit. It just increases the tariff from six to 12.5 percent. The canned tuna quotas and the amount of imports over each year's quota, in millions of pounds, from 1992 to 2001 are as follows:81

An indication of the attractiveness of the U.S. canned tuna market can be seen in the large increases of canned tuna imported above the quota. In 2003, an unprecedented 501.6 million pounds of canned tuna entered U.S. commerce above the quota level. This amount is more than twice the amount over quota in 1999 (249 million lbs.) and a 55 percent increase over 2002. These data suggest that even with an increased duty rate of from six to 12.5 percent, foreign suppliers can realize a profit in the U.S. market. The relatively small differences in quotas each year do not explain the very large differences in amounts over quota.

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European Tariffs

The International Trade Commission (ITC) concluded that the higher European Union (EU) tariff of 24 percent reduces the quantity of imports to Europe by a large amount. It depresses the world price of tuna, lowering the cost of imported tuna in the U.S. market. As a result, U.S. consumers substitute away from U.S. domestically produced tuna to imported tuna. In 1992, it was estimated by the ITC that the EU tariff reduced the price of U.S. domestic canned tuna by 4.4 percent and the quantity of production by 8.8 percent.

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Use of Frozen Loin Technology

Tuna processors have suggested that one result of higher minimum wages could be replacement of manual fish cleaning and related jobs by tuna loin technology. Tuna loins are the lighter meat, edible portion of tuna, similar to fillets. Thawing, cooking and cleaning frozen, whole tuna produces them. The loins are then packaged—usually in vacuum-sealed plastic—frozen, and shipped to canneries. The production of tuna loins from the cleaned, whole fish amounts to 70-80 percent of the total labor cost. Given its labor-saving potential, the use of frozen, precooked tuna loins as a raw material by some processors has increased. By shifting the production of loins to locations with relatively low labor costs, canned tuna producers can reduce labor costs significantly.

A plant in the Marshall Islands has been producing tuna loins for several years and sending the loins to StarKist Samoa for further processing. As of 2001, StarKist Samoa was in negotiations to acquire frozen loins from a facility to be constructed in Papua New Guinea. According to StarKist officials, average wages in the Marshall Islands and Papua New Guinea were approximately $US 2.00 and $US 0.24 per hour, respectively.82

StarKist has two plants in Ecuador producing frozen loins, which were shipped to its Puerto Rico Caribe plant for canning. The shift from frozen whole fish to tuna loins as the supply for the Puerto Rican cannery contributed to a decrease in employment by about 1,500 employees in Puerto Rico, prior to that location’s closure. Frozen loins were purchased from lower labor-cost foreign producers, canned tuna was bought from lower labor-cost copackers in Thailand, and production in relatively low-wage American Samoa (compared to Puerto Rico) was increased.83 In addition, substantial capital investment was made by StarKist to increase its output capacity by 10-15 percent in order to can imported frozen loins in addition to whole fish at its plant in American Samoa.

Chicken of the Sea, the second tuna processor in American Samoa, did have a cannery in Los Angeles using frozen loins. In 2001, that facility was closed and the 100 ton/day production was moved to American Samoa.84 In 1990, Bumble Bee opened a cannery in California that exclusively processes loins. Virtually all loins utilized by U.S. canneries are imported.

In addition, by producing the loins in a foreign country with less stringent environmental regulations, the cannery need not concern itself with disposal of the waste products in the more regulated U.S. territory of American Samoa. This concern was a factor in the movement of the U.S. canned tuna industry from the mainland U.S., particularly California, during the 1980s.

Importing loins into the continental United States, as Bumble Bee does, provides an advantage over shipping in and putting its brand name on tuna cans produced in a lower cost foreign country. Shipping costs for loins packed in plastic are lower than shipping costs for tuna packed in metal cans. There are also tariff savings to importing loins. The duty on loins is only 0.5 cents per pound (1.1 cents per kilogram), while canned tuna imports are dutiable at six, 12.5 or 35 percent of value (ad valorem), depending on the tariff category.

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Economic Uncertainty

When economic growth in a given region or industry is robust, there is more leeway to increase wages. While acknowledging the past growth of the tuna processing industry, in April 2000, a report on the future of the American Samoa economy concluded…

"There are strong probabilities that American Samoa could face drastic economic setbacks in this decade."

The report was titled "Comprehensive Economic Development Strategy," and was written by the Territorial Planning Commission and Department of Commerce of the American Samoa Government. The U.S. Department of Commerce, Economic Development Administration funded this report.

The report stated that Federal government aid and the tuna industry constitute roughly 90 percent of the island's economy. The income of the 8,200 workers of the American Samoa Government and the tuna industry support the other 5,700 workers in various industry establishments on the island. It found that 60 percent of the jobs in American Samoa are either cannery jobs or cannery-related, or jobs that only exist because of tuna workers.

In the 1980s, Federal aid increased nine percent a year. But in the 1990s, it increased less than one percent a year, actually falling by 3.6 percent a year after adjusting for inflation. The report focused on the lack of adequate infrastructure to attract new industry (e.g., industrial park, water, sewer and power), although acknowledging such infrastructure is far more developed than in many areas of the Pacific Basin.

The report stated:

"The economic growth that has occurred over the last several decades has not done very much to raise American Samoa’s standard of living…and the reason for this [decline in real personal income] is that the private sector development that has occurred has been offset by large-scale in-migration. In other words, instead of increasing the average wages of resident workers, most of the new income went to in-migrants."

The positive impact of gains in the minimum wage in terms of increased spending in the American Samoa economy is somewhat blunted by the presence of so many Samoan workers who reside in American Samoa, usually renting rooms in homes of American Samoans. Some part of their wages is spent in Samoa's economy, a factor that diminishes the potential of economic growth of American Samoa. In the tuna canneries and other sectors, the great majority of low-paid workers are from Samoa, an independent nation with average hourly earnings far below American Samoa's.85 The American Samoan government collects taxes based on their earnings, but Samoans do not have representation as American Samoa citizens.

The report noted that the tuna canneries have been able to thrive due to low wages, low taxes, location, and preferential trade terms. It stated, however, that "time is running out on American Samoa's low wage, labor intensive industries (such as American Samoa tuna canning and garment factories) primarily because the artificial location advantages upon which they depend (e.g., tariffs and quotas) are disappearing." It called for new industry with higher productivity levels equal to their income goals. Such higher productivity would be the result of better-educated, better-trained workers, a more efficient class of managers, and capital investment in new technology.

The 2004 State of the Economy Report expounded on the economic uncertainty of the island. Despite hurricane Heta causing massive devastation to the island in January of 2004, the aid brought to the island from government money and volunteering efforts softened the economic impact, but inflation still rose. The report indicated that increases in global oil prices were a component affecting the inflation on the island. American Samoa has gone through tumultuous times with the airline industry. Aloha Airlines unexpectedly decided to suspend service to the island, leaving Hawaiian Airlines as the sole airline for passenger travel to the U.S. mainland. In addition, the suspension of service of Samoan Air by the Federal Aviation Administration (FAA) left Polynesian Airlines with a monopoly on inter-island travel. American Samoa relies on travel from the U.S. mainland as a primary source of their tourism revenue. High prices in airfare to the island could hinder travel and the amount of tourism revenue to the local economy.

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Wage Increases Not Limited to Minimum Wage Workers

In most internal labor markets, i.e., markets governed by institutional rules, such as civil service systems or large private employer personnel systems, an increase in the entry-level wage may lead to wage increases in other job classifications in order to maintain relative occupational pay relationships.

According to StarKist and Chicken of the Sea officials, any increase in the minimum wage has also been applied, sometimes by change in percentage, sometimes by absolute cents, to all wage classes in their canneries to avoid wage compression and to maintain incentives for employees with higher-level skills and with more experience. Therefore, according to industry sources, it is not just those paid at or below the minimum wage who receive a wage increase when minimum wage levels are raised, but many additional employees do as well.

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High Failure Rate of Small Businesses

Small businesses in American Samoa have a high failure rate, due to cash flow problems, poor management, low-quality products, insufficient advertising and under capitalization. Testimony submitted by the Department of Commerce for the 1999 hearings held by Committee No. 23 listed these factors. To the extent that small businesses are covered, a higher minimum wage may add to their problems. 86

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Higher Wages than Competitors

Attempts to compete with nearby islands for new industry are also hindered by increases in the American Samoa minimum wage. As of 2003, the minimums in such locations were $0.71 USD in Tonga, $0.54 USD in Samoa, and $0.71 USD in Fiji's manufacturing trade.87

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Currency Devaluation

The 1997-98 economic crisis that led to devaluation of currency for Thailand and many other Southeast Asian nations increased their ability to compete, given that the dollar purchased more value in their devalued currencies.

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Other Economic Disadvantages of the American Samoa Location

In its 1999 testimony, a Chicken of the Sea representative cited ocean and airfreight costs and infrequent arrivals and departures as negatives for the American Samoa location, compared to some other sites. OSHA and EPA regulatory costs were also cited, as well as a high absenteeism and turnover rate for some workers in American Samoa. These various costs, if compounded by a higher minimum wage, could lead to relocation of some production to lower-wage locations.


65. Sources: Various papers delivered at Tuna 1997 Conference in Bangkok.
66.U.S. Department of Commerce, Fisheries of the United States, 2003, NOAA.
67.Quotations and other data in this section are from pp. 87-90 (paper by Mr. Lischewski) and pp. 113-118 (paper by Mr. Krampe), Tuna 2000 Bangkok: Papers of the 6th World Tuna Trade Conference, May 25-27, 2000, Bangkok, Thailand, edited by S. Subasinghe and Sudari Pawiro, published by INFOFISH (2000).
68.BLS data indicate the same trend. Between 1994 and 2004, the real price of light meat canned tuna fell from $1.40 per pound (in 1982-84 dollars) in 1994 to $0.98 per pound in 2004, a decrease of 30 percent.
69.Report of American Samoa Industry Committee Number 25, 2003.
70.Prehearing Statement of COS Samoa, Inc., Special Industry Committee No. 24, June 2001.
71.U.S. Department of Commerce, Fisheries of the United States, various years, NOAA.
72.Crow's Nest, September 2000.
73.Former European colonies in Africa, the Pacific, and the Caribbean, plus the Andean community nations, import canned tuna duty free.
74.Federal Register, Volume 68, Number 19.
75.San Francisco Chronicle, U.S. Judge Affirms Tuna Rules, August 11, 2004.
76.http://www.defenders.org/defendersmag/issues/summer02/tunadolphin.html.
77.http://www.usitc.gov/er/nl2002/ER1008z1.htm.
78.http://www.house.gov/apps/list/press/as00_faleomavaega/andean1001.html.
79.http://www.house.gov/apps/list/press/as00_faleomavaega/atpapasseshouse.html.
80.http://www.house.gov/apps/list/press/as00_faleomavaega/atpapassedbysenate.html.
81.U.S. Department of Commerce, Fisheries of the United States, 2003, NOAA. Note from publication:—Data in this table will not agree with tuna import data released by the U.S. Department of Commerce, Bureau of the Census. Any tuna entered for consumption or withdrawn from a warehouse for consumption during the calendar year, except for receipts for possessions of the U.S., is subject to this quota.
82.Prehearing Statement of StarKist Samoa, Inc., Special Industry Committee No. 24, June 2001.
83.Testimony of Barry Mills, Vice President of Tuna Operations for the Star-Kist Tuna Company, pp.16-22 of transcript, June 8, 1999. Submitted to and given at public hearing held by Industry Committee No. 23.
84.Crow’s Nest, August, 2001.
85.In 1995 there were 6,609 persons in the labor force of 14,700 who were born in American Samoa; 6,510 were born in Samoa; the remainder were born in Tonga, other Pacific islands, U.S. mainland, and elsewhere, according to the American Samoa Statistical Yearbook, 2000, Department of Commerce, American Samoa Government.
86.The minimum wage must be paid to all non-exempt employees by employers with a gross annual dollar volume of sales in excess of $500,000. In addition, the minimum wage must be paid to non-exempt employees who are engaged in commerce, in the production of goods for commerce, or in activities closely related or directly essential to the production of goods for commerce.
87.Prehearing Statement of American Samoa Government, Special Industry Committee No. 25, 2003.