Effective Associating Advocacy to Advance our Members
PMPA’s mission is to provide information, advocacy and networking opportunities that advance our members.
PMPA’s mission is to provide information, advocacy and networking opportunities that advance our members. Where do you turn to get guidance and clarity to make clear your responsibilities in each of these areas?
European Environmental Regulations
End of Life Vehicles (ELV), Waste Electrical and Electronic Equipment Directive (WEEED), Restriction of Hazardous Substances (RoHS II Recast) Registration, Evaluation Authorization and Restriction of Hazardous Chemicals (REACH) present a challenge to precision machining shops, and in some cases, explicitly forbidding certain free machining additives, only to exempt them in special circumstances. PMPA provided our members with clear guidance on these back in 2005 and have kept members up to date ever since. If you don’t know the latest on RoHS II, for instance, you could be at a disadvantage to PMPA members who know which free machining additives are exempt and for how long.
Conflict Minerals (Dodd Frank)
PMPA has been active on this regulation even before it was implemented. We evaluated potential impacts, commented on aspects that would have made almost every steel reportable (fortunately, those aspects weren’t included in the final rule) and even signed on to an amicus, which was upheld by the U.S. Supreme Court. PMPA members have clear guidance on how to deal with their customers’ demands for conflict minerals reporting and compliance on products made-to-order by our shops from materials specified by our customers.
California Proposition 65
PMPA has provided our members with guidance as these regulations continue to evolve. Covered substances, warnings, conditions and circumstances indicating the need for warnings and other guidance have been made available for PMPA members on our website, as well as via our Listserves for specific questions. For example, our members have access to the latest authoritative compliance information on metallic nickel, an item that is problematic. Do you know what you need in order to comply with your products?
Beryllium regulations were recently updated by the federal government. PMPA advised our members on the potential impacts before these were even published. If you are machining Beryllium-containing materials and you are not aware of the latest updated regulations, you could be in for a quite unexpected surprise.
But effective advocacy is more than reporting what is on the books. PMPA is active in looking ahead at items that could have impacts on our shops and getting involved at both legislative and agency offices with comments and testimony. Here is a sampling of the issues we believe we will be working on, on behalf of our members, in 2019:
Waters of the U.S.
That drainage ditch at the back of your parking lot should not be considered a navigable waterway. PMPA expects a final rule late this summer.
Powered Industrial Trucks
Powered industrial trucks are an essential part of manufacturing, and the standards covering them have not been updated since the ANSI standards were adopted in 1969.
Lockout/tagout is getting attention from OSHA and trying to reconcile today’s computerized controls with the 1980s-era safeguards of the existing standard. Precision machining equipment in our shops can be sourced from manufacturers in Europe, Asia and the U.S., all of which develop hazardous energy controls to different standards. PMPA will be taking an active role in assuring that modernized and updated standards offer effective employee protection while not causing an undue burden on setup adjustment and return to operation.
Joint employer rules, power presses update, bonus depreciation, 199A pass-through deduction, non-qualified deferred compensation, duty drawback process and Section 232 Exclusions are items that we are watching. We expect to issue comments or take other actions involving rulemaking for the “Injury and Illness Preamble Final Rule, Conflict Mineral Rule” (it’s in District court), and we will remain involved in all of the activity on TCE and TCE vapor degreasing.
PMPA’s mission is to provide advocacy to advance our members. Who is advocating in all of these areas on behalf of you and your shop?