TCMA Industry News
AFS Government Affairs Committee Meeting
   Stephanie Salmon  |  December 5, 2012

Helix The AFS Government Affairs Committee Meeting convened at 1:15 pm CT on Wed. December 5 and was led by AFS Government Affairs Committee Chairman, Brad Muller, Charlotte Pipe and Foundry. The AFS Washington Office prepared three documents covering workplace, environmental and tax/trade issues of interest to the foundry industry.

During the meeting, we discussed the following key issues:

Completion of Report on the Potential Costs of the Ancillary Provisions of a Crystalline Silica Rulemaking
The Committee had an opportunity to hear an overview of the recently completed report estimating the costs to the metalcasting industry of the potential “ancillary requirements” that are likely to be included in a new occupational exposure standard for crystalline silica that that the Occupational Safety and Health Administration (OSHA) is developing. Study Sessions of Environomics, a highly regarded economist, is the author of the AFS-funded study. He provided the summary of the study via conference call.

The potential silica regulation will likely include a new Permissible Exposure Limit (PEL) that we believe would cut the current PEL in half, to 50 ug/m3, as well as an Action Level. The wide variety of ancillary requirements to accompany this tighter standard, will likely include requirements that employers must conduct exposure monitoring for silica; must provide medical surveillance for workers for silica-related illnesses; must identify work zones where silica exposures may exceed the PEL, mark these zones and limit access to them; must provide training regarding silica hazards; and more.

Stu discussed how the foundry industry is the particular industrial sector that appears likely to be most affected by a new silica regulation. Based on this in-depth study, Environomics estimates the costs for the U.S. foundry industry to comply with OSHA’s nine probable sets of ancillary requirements would be $350 million to nearly $500 million per year, depending on the particular Permissible Exposure Limit (PEL) and Action Levels that are chosen by OSHA. These costs for compliance with the potential silica ancillary requirements are very alarming, averaging about $175,000 per foundry per year for the least costly of the three PEL/Action Level alternatives and nearly $250,000 per foundry per year for the most costly alternative. Environomics notes that these costs amount to 1 to 2% of total U.S. foundry industry revenues as of 2007, the most recent year for which a nationwide estimate of revenues for our industry is available.

The costs for the ancillary provisions are separate from the costs for the engineering controls. In a report conducted in 2011 by Environomics and funded by the Silica Panel (AFS is a longstanding member), compliance costs for the foundry industry were estimated at more than $1.5 billion/year for the engineering controls alone, if the current PEL is cut in half as anticipated.

AFS Action: AFS is in the process of setting up a meeting with OMB/OIRA to discuss the findings of on the costs of the potential ancillary requirements on the foundry industry. In addition, AFS will be meeting with targeted Hill staff and the office of Advocacy of the Small Business Administration in the upcoming weeks.

Outreach to New Congress
With nearly 100 new members of Congress – The Committee talked about various ways to reach out to new all of these new lawmakers.

AFS Action: AFS is sending a Welcome letter to every House & Senate lawmaker – that letter will go out the week of January 14. We are almost finished with matching every foundry by state with their lawmaker for the new 113th Congress (including non-AFS members). We will be sharing that excel spread sheet by the end of the month with AFS and the GAC. AFS members will be able to identify their lawmaker. In addition, we are in the process of developing a two page color document that is a general overview of the foundry industry which can be tailored to fit every state where we have foundries. In the weeks and months ahead, the AFS Washington Office will continue to meet some of these new lawmakers and their staff. We encourage all of you to make time to meet these members back in your state as well.

AFS Priority Issues for 2013
Following an overview of environmental and OSHA issues and discussion of potential issues for 2013, the Committee voted on the following five issues to be the focal point of the industry’s efforts in Washington in 2013:

1. EPA: Ozone
2. OSHA: Crystalline Silica
3. Other Safety & Health Issues: Injury & Illness Prevention Rule & Combustible Dust + Enforcement
4. Energy – Create 2 pager on importance of energy to US Foundries – work with AFS Marketing Committee
5. Regulatory Reform

As other issues develop over the course of the year, we will add them as priority issues as necessary. AFS will continue to be engaged and sign onto coalition letters regarding implementation of the Affordable Care Act (aka Obama Care), infrastructure matters, environmental and energy issues, and NLRB matters.

AFS Government Affairs Conference
This year’s Conference, May 1-3, will once again be held at the JW Marriott Hotel. A working group has been formed and will be meeting shortly to finalize a paid speaker and work on putting together a strong program. During the meeting, we noted that unfortunately Congress will not be in session during the week of the conference. We will once again work to have high level staff meetings in the personal offices, as well as with top committee staff dealing with EPA and OSHA issues. We also discussed having strong promotion of the conference.

The meeting convened at 4:30 pm CT. The next Committee will be scheduled some time in March. A meeting Notice will be sent out in early February.