MAMF Merges with Grand Rapids NASF

The MAMF board is pleased to announce the merger of the Michigan Association of Metal Finishers with the Grand Rapids NASF. The merged group will be called The Michigan Chapter of NASF.

Since the NASF merger of AESF, NAMF and MFSA has been a success, both MAMF and GRNASF decided it is time the branches and affiliates work together to strengthen our industry as the NASF on a local level.

Both groups have a long history of active membership and involvement, with MAMF strong in advocacy and GRNASF strong in education. Bringing these groups together gives us a bigger presence here in Michigan, as well as with our national association, the NASF.

A workgroup has been formed with representatives from both boards to make decisions on by-laws, a new website, and any other official business. Once the decisions are made, an official election will take place to vote on the new Michigan board.

This is exciting news, and makes our voice in the industry stronger than ever!

Thanks, as always, for your continued support.

Posted in NASF Chapters

California Finishers Make Voices Heard

NASF Metal Finishers of Southern and Northern California brought members face-to-face with the decision makers in the State of California who determine the outcome of their industry’s top State legislative priorities at their annual West Coast Finishers Legislative Day held April 5th and 6th in Sacramento.

This strong grassroots program connects industry leaders in California with policy makers and creates the opportunity to discuss and describe the role of the industry in the manufacturing supply chain and the entire state economy.  Coming off the heels of the recent NASF Washington Forum, participants were well prepared to discuss both National as well as State-wide issues impacting their companies and further describe just how pervasive and important surface technology is.

Benefits of this year’s program included:

  • Extensive lobbying at the grassroots level- telling the surface finishing story
  • Inside briefings from experts on issues critical to the industry
  • Face-to-face meetings with members in office connecting constituents and their businesses with their legislators
  • Widespread networking with decision-makers and colleagues
  • A lesson in the importance of participation

It’s all about strength in numbers, and the California Chapters certainly turned out and made their voices heard. The annual event was organized by MFASC President Bryan Leiker, MFANC President Terry McGuinness and executed by California Chapters Legislative Advocate Jerry Desmond and Executive Director Norman Plotkin. The 2015 California Legislative date will be announced once officials have locked in the dates.

 

 

Posted in Government Relations, Law & Regulation, NASF Chapters

NASF Challenge of EPA’s Chromium Electroplating Air Emissions Rule

EPA promulgated a new chromium electroplating and anodizing rule in September 2012 that imposes more stringent emissions limits and surface tension levels.  The rule also bans the use of PFOS-based fume suppressants as of September 2015.  The new emission limits and surface tension levels become effective in September 2104.  EPA’s rationale for rule is based on inaccurate data, faulty technical assumptions, and poor science.  The final rule could require facilities to install expensive emissions control equipment, because the proposed compliance options identified by EPA are not proven to be effective.  In addition, in promulgating this rule EPA has attempted to expand its authority under the Clean Air Act (CAA) in an unprecedented fashion.

NASF filed a legal challenge to the final rule in the U.S. Court of Appeals for the D.C Circuit claiming that EPA has misapplied the requirements of the CAA and failed to provide any credible technical support for the new standard.  Without this challenge EPA would be free to use its interpretation of the CAA and approach for setting new air emissions requirements in this rulemaking and to other plating processes such as nickel in future rulemakings.  NASF must also defend against a further tightening of the emission limits because the Sierra Club has also filed a legal challenge to the rule, claiming that EPA did not set stringent enough emission limits.

In April 2014 NASF and Sierra Club filed their initial legal briefs in this case.  EPA, represented by the U.S. Department of Justice (DOJ), has several months to submit its brief in response to NASF and Sierra Club.  Following the submission of DOJ’s brief, NASF will have an opportunity to submit a reply brief.  By August 2014 the final briefs will be filed with the court and an oral argument will be scheduled, hopefully in Fall 2014.  During oral argument, the parties will have an opportunity to make their final presentations to the court and answer any specific questions that the judges may have.  After that, the court will issue its opinion on whether EPA acted appropriately.

The legal issues presented in this case are precedent setting and will have impacts on many other industries.  For example, Sierra Club has made an unusual request that the entire roster of D.C Circuit judges hear this case so that it can revisit some previously established interpretations of the Clean Air Act.  In addition, because EPA has attempted to expand its authority under the CAA in this case, several large industry trade groups will be submitting an amicus curiae (friend of the court) brief in support of the positions taken by NASF in this case.  The American Lung Association and Air Alliance Houston will be supporting the Sierra Club as friends.

The challenge of EPA’s rule is critical not only for chromium electroplating, but also for other types of surface finishing as well as other industrial activities as EPA attempts to expand its authority under the CAA.  Many NASF members and other surface finishers have already made generous contributions to NASF to support this effort to protect the best interests of the surface finishing industry and defend against the promulgation of even more stringent new standards.  For more information on how you can contribute to defending the industry from inappropriate and unnecessary regulation such as the chromium electroplating and anodizing rule, please visit the NASF website at nasf.org or contact Jeff Hannapel at jhannapel@thepolicygroup.com.

Posted in Government Relations, Law & Regulation, NASF National

NASF Chapter News

Congratulations to John Cutchin, owner of Palmetto Plating Company, on the celebration of the company’s 50th anniversary in business. Palmetto started its company by plating baby shoes. It grew steadily as a job shop and a major player in the southeastern United States.

Palmetto Plating has also announced that Paul Frank has been appointed to Executive VP and General Manager for the company. Paul brings over 45 years of electroplating and metal finishing experience and will manage the daily operations of Palmetto Plating.

Posted in NASF Chapters

Immigration-Reform Advocates Don’t Know What to Do Next

Immigration reform was once a real thing on Capitol Hill. Lawmakers huddled in secret; political risks were calculated and taken; tentative deals were struck. But now, despite some suggestions from Sen. Chuck Schumer about a lame-duck legislative fix, there’s really no chance of an overhaul of the dreadful U.S. immigration system. The groups lobbying for reform have failed to gain traction with their strategy of shaming Republicans into action, leaving advocates confused and conflicted about where to go next.

Click here for full article

Posted in Government Relations, Law & Regulation

Feel Sluggish? It’s an Extra 20 Pounds or 30 Years of Regulatory Burdens

According to the Manufacturers Alliance for Productivity and Innovation (MAPI), since 1981 federal agencies have promulgated approximately 2,300 manufacturing-related regulations.  This equates to 1.5 regulations every week for 30 years.  About one half of the 2,300 federal rules impacting manufacturing were issued by the U.S. Environmental Protection Agency (EPA).  Over the last 15 years, the compliance costs associated with these EPA rules are $177 billion, which is more than all other federal agencies combined over that same period.

These federal rules have imposed a significant regulatory burden on U.S. manufacturing without any formal assessment of the cumulative cost to industry.  EPA was not required to conduct a cost-benefit analysis for over 90 percent of its rules, because they were not designated as “significant” (a significant rule is defined as a rule that has an impact of $100 million or greater on the U.S. economy).  Accordingly, the cumulative impacts of these EPA rules (that separately make a small incremental addition to the regulatory burdens on U.S. manufacturing) have been layered over 30 years to result in a significant impact.

In addition to this legacy of cumulative regulatory burdens, this trend has been accelerated in the past decade.  Despite the gridlock in Congress, the Executive Branch has been very active and looks to remain active in the near future.  The Federal Register is a public record of all the final and proposed regulations from federal agencies, as well as other regulatory activities of the federal bureaucracy.  In 2013 the Federal Register included 79,311 pages, 3,659 final rules (representing new regulatory burdens), and 2,594 proposed rules (representing future regulatory burdens).

The 2013 Federal Register page count was the fourth highest total in history.  The all-time record for Federal Register page total was 2010 with 81,405 pages.  The Obama Administration has been particularly active with regulatory initiatives claiming four of the five highest Federal Register page totals in U.S. history.  There is also no sign that this regulatory juggernaut will let up anytime soon.

The Competitive Enterprise Institute (CEI) estimates that the overall regulatory compliance cost and its economic impact is approximately $1.9 trillion annually.  Not only does this regulatory tax hurt the competitiveness of U.S. companies, but it also increases the prices of goods and services.  According to the CEI, U.S. households may pay nearly $15,000 annually in this hidden regulatory tax, which would be just less than 25 percent of the average U.S. household income of $65,596.

The good news is that the Obama Administration recognized the need for regulatory reform.  President Obama issued Executive Order13610: Identifying & Reducing Regulatory Burdens and Executive Order 13563: Improving Regulation and Regulatory Review.  These actions were designed to 1) modernize the regulatory system and reduce unjustifiable regulatory burdens and costs and 2) ensure that a regulation is inherently informed, that it delivers big economic and other benefits, and that it doesn’t compromise economic growth and job creation.  As part of these efforts, federal agencies were asked to develop retrospective regulatory review plans and make regulatory programs more effective or less burdensome in achieving regulatory objectives

The Obama Administration claimed that retrospective regulatory review effort was expected to save U.S. businesses and consumers $12 billion over the next five years.  Unfortunately, the results have not been as anticipated.  Although more than 500 regulations were reviewed and reconsidered, the process has resulted in more than 1.5 billion hours of paperwork and $10.2 billion in new regulatory costs.

The 30-year legacy of regulatory burdens appears that it will continue, if not accelerate, for U.S. businesses.  While the regulatory burdens are not the only reason for a sluggish U.S. economy, they are a significant contributor.  U.S. companies must look for opportunities to innovate, reduce costs, and increase productivity to remain competitive globally.

Posted in Government Relations, Law & Regulation

Essentials for a Successful Safety Initiative

Safety affects every aspect of the enterprise, from the plant floor to the boardroom. While historically safety has been a local concern, and always will remain so in that a breach of safety takes place at a particular site, approaching safety from a global perspective leads to the application and enforcement of standards and best practices that move safety toward its ultimate goal: making the workplace safe for all employees. Understanding the value of safety is a key aspect of this perspective. If companies approach safety purely from a cost or regulatory focus (i.e., merely as “an insurance policy”), the positive impact of safety initiatives often falls short of their potential.

Click here for full article

Posted in Law & Regulation

Favorable Court Decision on Conflict Minerals Rule Generates More Uncertainty

As part of the Financial Reform Act of 2010 and regulations promulgated by the Securities Exchange Commission (SEC) companies subject to SEC reporting requirements that use gold, tin, tantalum and tungsten in their products must disclose information in reports submitted to the SEC.  The disclosure must include statements that these materials are necessary to the functionality or production of the product and whether the materials originated in the Democratic Republic of the Congo (DRC) or adjoining countries.

Industry groups challenged the SEC regulation in the U.S. Court of Appeals for the D.C. Circuit.  On April 14, 2014 the D.C. Circuit ruled that the statute and regulation were unconstitutional and violated the First Amendment because it required companies to disclose that one or more of their products have ‘not been found to be DRC conflict free.”  Specifically, the court concluded that the statute and regulation were unconstitutional to the extent that they required companies “to tell consumers that its products are ethically tainted, even if they only indirectly finance armed [militant] groups” in the DRC or are unproven not to support these groups.

The D.C. Circuit did not overturn other portions of the regulation as requested in the industry challenge based on concerns over failure to include a de minimis exception or the adequacy of the cost-benefit analysis of the rule.  Accordingly, industry groups have asked the SEC to stay the requirements of the conflict minerals rule or to provide guidance consistent with the court’s ruling on what information must be included in the first disclosure reports that need to be submitted to the SEC by June 2, 2014.

On April 29, 2014, the SEC issued guidance stating that in filing the first conflict minerals disclosure reports, companies do not have to describe their products as “DRC conflict free,” “not been found to be DRC conflict free,” or “DRC conflict undeterminable.”  This in attempt to avoid the First Amendment concerns regarding disclosure that were raised by the court.

Arguably, under this guidance companies would still need to:  1) determine if they are covered under the rule; 2) make a reasonable country-of-origin inquiry regarding the conflict minerals in their products; and 3) conduct due diligence on the source and chain of custody of the conflict minerals in their products.  It is not clear what purpose the conflict minerals disclosure reports will now serve if companies do not have to disclose whether their products are DRC conflict free.

For the short-term, companies are still required to submit conflict minerals disclosure reports (without the conflict free determination punch-line) to the SEC by June 2, 2014.  While further clarifications are still needed on this issue and whether the regulation now serves its intended purpose, more challenges to the requirements are likely and new developments will be emerging in the next few months.

For more information on this topic, contact Jeff Hannapel with NASF at jhannapel@thepolicygroup.com.

Posted in Government Relations, Law & Regulation

Local Chapter Welcomes Finishers to Cleveland June 9th

Reservations are still being taken for the popular NASF SUR/FIN Welcome Party hosted by the Ohio Chapter of Metal Finishers. This not-to-be-missed event will take place Monday evening, June 9th at The Corner Alley, one of Cleveland’s most exciting hot spots – all are welcome for cocktails, heavy appetizers, bowling and billiards.

All profits will go to support the NASF 1000 to advance the industry’s legal and policy agenda.

See the OAMF flyer for more details on the event.

Posted in Events, NASF Chapters

NASF SUR/FIN 2014 Kicks Off June 9th In Cleveland: Ford Motor Co.’s Drobnich to Keynote

The NASF’s SUR/FIN Manufacturing and Technology Tradeshow and Conference kicks off its 96th year at the Cleveland Convention Center June 9-11, 2014.  In addition to a sold out exhibit floor, this year’s conference will feature 90 expert speakers and an informative keynote presentation from Mr. Duane Drobnich of Ford Motor Company. Mr. Drobnich leads a team of highly experienced engineers in the development and implementation of new finishing technologies and is also responsible for global design and commonality strategies.

June 9: 1:00pm – 6:45pm

June 10: 8:00am – 4:30pm

June 11: 8:00am – 3:00pm

Register online at nasfsurfin.com

Posted in Events, NASF National