Tag: TRI

Burdensome Regulations- Letter to House Oversight and Government Reform Committee Chair Darrell Issa

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We sent our letter to attention of Chairman Darrell Issa…

Earlier this month,  Precision Machined Products Association (PMPA) submitted a  joint letter with NTMA and PMA in response to a request by House Oversight and Government Reform Committee Chair Darrell Issa for examples of ill-conceived regulations and rules interpretations and their impact on metalworking manufacturers.

The letter stated, “The first week of May 2012, the federal government issued 77 new final rules and regulations and proposed 40 new rules. As of May 25, 2012, the year-to-date total for new federal rules and regulations issued was 1,506, filling 31,432 pages. Of these new rules, the government classified 292 as having a significant impact on small businesses. Companies like our members simply lack the resources, financial or personnel, to sort through the thousands of pages of new regulations each year. Compounding this challenge is a lack of knowledge of industry process by regulators who are not familiar with manufacturing and therefore often issue ineffective rules with unintended consequences.”

The letter provided examples of existing and proposed regulations and rules interpretations that negatively impact metalworking manufacturers, reduce global competitiveness and restrict the ability to hire employees and invest in facilities. Examples included the EPA’s TRI Article Exemption Rule, Nickel Rule and Metalworking Financial Responsibility Requirements Rule; OSHA’s interpretation of lockout guidelines, arc flash requirements and guidance memo indicating that safety incentive programs may potentially be a discriminatory violation against disciplined employees and may discourage safety violation reporting; and the SEC’s conflict minerals rule. Read the full letter.

You have more than enough on your plate to say grace over without having to battle the bureacrats and regulators and their ill conceived burdensome regulations.  PMPA’s regulatory efforts are just one way of  “effective associating” that can help you and your company in today’s hostile regulatory environment.

Regulatory Reform- EPA Article Exemption "Clarification" Withdrawn

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 On June 17th, at the request of the US Environmental Protection Agency, the Office of Management & Budget removed from its list of Submissions Under Review (http://www.reginfo.gov/public/do/eoDetails?rrid=119517 ) the EPA proposed final “Toxics Release Inventory (TRI) Articles Exemption Clarification Rule.”
The proposed rule would have eliminated the articles exemption under TRI and required manufacturers to report releases from finished goods in storage.
Finished goods in storage!
 Here’s the rest of the story:
Last July PMPA attended a meeting in Washington D.C. with OMB and EPA over a proposed EPA “Clarification” regarding the article exemption in TRI.
We were joined at that meeting by a number of other involved parties with similar concerns. The meeting was hosted by Jeff Miller of the Treated Wood Council.
We opposed the change and challenged the EPA’s estimate of Paperwork Burden, demonstrated impact on smaller businesses, and made other technical points.

Paperwork burden and manhours to prepare were just the tip of the iceberg.

You can see our Business Intelligence on this issue here .
The EPA’s proposed  change in the “clarification” could have made finished precision machined products with rust preventives subject to TRI release reporting.
At EPA’s request, this submission was removed from review.
We are pleased that our attention to this regulatory issue  with other affected industries has resulted in its withdrawal at the current time. Our position was that the EPA cannot change the TRI rule without formal rulemaking.    Members of Congress have echoed that same concern.   
EPA may ultimately decide to initiate that rulemaking process.  
We do not know exactly why EPA withdrew the proposed rule, nor do we know EPA’s next steps.  
There is nothing transparent about regulation of  small business in Washington D.C.
But for now, as a result of our “effective associating”  and engagement with the federal agencies involved, this ill-considered change to TRI has been withdrawn.
 We will continue to monitor this issue and keep you informed of any developments.
Paperwork Photo :