Financial report context:
concentration of credit risk credit risk represents the accounting loss that would be recognized at the reporting date if counterparties failed to perform as contracted . the company believes the likelihood of incurring material losses due to concentration of credit risk is remote . the principal financial instruments subject to credit risk are as follows : cash and cash equivalents - the company maintains cash deposits with major banks , which from time to time may exceed insured limits . the possibility of loss related to financial condition of major banks has been deemed minimal . additionally , the company 2019s investment policy limits exposure to concentrations of credit risk and changes in market conditions . accounts receivable - a large number of customers in diverse industries and geographies , as well as the practice of establishing reasonable credit lines , limits credit risk . based on historical trends and experiences , the allowance for doubtful accounts is adequate to cover potential credit risk losses . foreign currency and interest rate contracts and derivatives - exposure to credit risk is limited by internal policies and active monitoring of counterparty risks . in addition , the company uses a diversified group of major international banks and financial institutions as counterparties . the company does not anticipate nonperformance by any of these counterparties . cash and cash equivalents cash equivalents include highly-liquid investments with a maturity of three months or less when purchased . accounts receivable and allowance for doubtful accounts accounts receivable are carried at their face amounts less an allowance for doubtful accounts . accounts receivable are recorded at the invoiced amount and generally do not bear interest . the company estimates the balance of allowance for doubtful accounts by analyzing accounts receivable balances by age and applying historical write-off and collection trend rates . the company 2019s estimates include separately providing for customer balances based on specific circumstances and credit conditions , and when it is deemed probable that the balance is uncollectible . account balances are charged off against the allowance when it is determined the receivable will not be recovered . the company 2019s allowance for doubtful accounts balance also includes an allowance for the expected return of products shipped and credits related to pricing or quantities shipped of $ 15 million as of december 31 , 2015 and 2014 and $ 14 million as of december 31 , 2013 . returns and credit activity is recorded directly to sales . the following table summarizes the activity in the allowance for doubtful accounts: .

Financial table:
( millions ): beginning balance; 2015: $ 77; 2014: $ 81; 2013: $ 73
( millions ): bad debt expense; 2015: 26; 2014: 23; 2013: 28
( millions ): write-offs; 2015: -22 ( 22 ); 2014: -20 ( 20 ); 2013: -21 ( 21 )
( millions ): other ( a ); 2015: -6 ( 6 ); 2014: -7 ( 7 ); 2013: 1
( millions ): ending balance; 2015: $ 75; 2014: $ 77; 2013: $ 81

Additional report context:
( a ) other amounts are primarily the effects of changes in currency translations and the impact of allowance for returns and credits . inventory valuations inventories are valued at the lower of cost or market . certain u.s . inventory costs are determined on a last-in , first-out ( lifo ) basis . lifo inventories represented 39% ( 39 % ) and 37% ( 37 % ) of consolidated inventories as of december 31 , 2015 and 2014 , respectively . lifo inventories include certain legacy nalco u.s . inventory acquired at fair value as part of the nalco merger . all other inventory costs are determined using either the average cost or first-in , first-out ( fifo ) methods . inventory values at fifo , as shown in note 5 , approximate replacement during the fourth quarter of 2015 , the company improved estimates related to its inventory reserves and product costing , resulting in a net pre-tax charge of approximately $ 6 million . separately , the actions resulted in charge of $ 20.6 million related to inventory reserve calculations , partially offset by a gain of $ 14.5 million related to the capitalization of certain cost components into inventory . both of these items are reflected in note 3. .

Question: what is the average percent of lifo inventories as a percent of consolidated inventories as of december 31 , 2015 and 2014?
Answer: 38