NFFS 2023 Annual Report

2023 Government Affairs

The NFFS Government Affairs Committee is charged with identifying the key regulatory and legislative issues that have the potential to affect foundries prior to their enactment, and to provide a cost-effective means of expressing the industry's concerns and interests to the appropriate government agencies and officials on a timely basis. Below is brief summary of the efforts taken by the NFFS Government Affairs Commitee (GAC) on behalf of NFFS members and the non-ferrous casting industry in 2023.

Tracking Issues

The following partial list of tracking issues identifies the wide variety of topics and issues considered by the NFFS Government Affairs Committee in 2023. Contact NFFS for additional information on any of the tracking topics listed below.

Comments Filed

NFFS Files Comments on OSHA's Proposed "Worker Walkaround Representative Designation Process"

On August 30, 2023, OSHA published a proposed regulation entitled "Worker Walkaround Representative Designation Process." The proposal allows third party representatives to participate in OSHA inspections, if requested by an employee, on the basis that they have “relevant knowledge, skills, or experience with hazards or conditions in the workplace or similar workplaces, or language skills of third-party representative(s) authorized by employees who may be reasonably necessary to the conduct of a CSHO's physical inspection of the workplace.”

NFFS submitted written comments on the proposed rule on behalf of NFFS member organizations and the non-ferrous foundry industry arguing that the rule contains significant concerns for the industry and urging OSHA to ensure that the proposed rule does not compromise workplace safety or employer rights. A copy of the submitted comments on [Docket No. OSHA–2023–0008] is available in its entirety in this article published in the November 1st issue of The Crucible.

Advocacy Letters

NFFS will often join forces with other manufacturing industry associations to work collaboratively to affect positive change for regulations that impact multiple different industry sectors. Below is a partial listing of the letters joined by the NFFS Government Affairs Committee in 2023:

• Reinstatement of the EBITDA Interest Deductibility Standard
  On November 29, NFFS joined other industry representatives in drafting a letter calling on Congress to act by year’s end to restore the EBITDA standards for interest deductibility.
• Letter Supporting Fight Against Discriminatory Regulations
  NFFS added its support to a letter to Congress asking them to fight for a level playing field against discriminatory regulations around the world that harm manufacturers. NFFS signed this letter to stand with manufacturers and urge the administration to fight discriminatory global regulations and push for a proactive agenda on standards, conformity assessment and regulation that allows critical market access for manufacturers large and small.
• Letter Urging Congress to Pass H.R.1 The Lower Energy Costs Act
  On March 20, NFFS joined the NAM in urging members of the U.S. House of Representatives to pass H.R. 1, the Lower Energy Costs Act, legislation to reform our burdensome permitting system and increase domestic energy and resource production. H.R. 1 makes significant strides to increase the production and export of American energy and reduce the regulatory burdens that make it harder to build major infrastructure through comprehensive permitting reform. 
• Letter: The Burden of Regulations Harms Manufacturing Growth
  On June 20, the Non-Ferrous Founders' Society (NFFS) joined the National Association of Manufacturers (NAM) in signing a joint letter to the Biden Administration as part of a shared goal to help highlight the impact of the regulatory onslaught facing manufacturers. Through its Manufacturers for Sensible Regulations coalition, the NAM and partner associations like NFFS, are respectfully urging the White House to support manufacturing competitiveness with tailored, consistent and targeted regulations. The letter requests that a senior level advisor be designated to coordinate efforts within the White House to ensure that federal regulators are implementing polices that align with the President’s promise to promote the growth of manufacturing in America.
  
• Letter Supporting the Fight Against Discriminatory Regulations
  NFFS adds their support to a letter to Congress asking them to fight for a level playing field against discriminatory regulations around the world that harm manufacturers. NFFS signed this letter to stand with manufacturers and urge the administration to fight discriminatory global regulations and push for a proactive agenda on standards, conformity assessment and regulation that allows critical market access for manufacturers large and small.
• Letter Urging Congress to Support Tax Policy Changes
  NFFS joined the National Association of Manufacturers (NAM) in calling for immediate action to extend three tax policies vital to workers and America’s immediate future: immediate R&D Expensing, a pro-growth interest deductibility standard and full expensing. The effort includes a multi-organizational letter calling on Congress to protect businesses' ability to continue to immediately deduct R&D expenses, finance job-creating investments through a pro-growth interest deductibility standard and fully deduct capital equipment purchases. Additional detail on this very important advocacy effort can be found in this article published in the October 25th issue of The Crucible.
• Letter to EPA Regarding Proposed Revision to NAAQSPM2.5 Standard
  The Environmental Protection Agency has proposed a discretionary revision of the National Ambient Air Quality Standards for fine particulate matter (PM2.5). The standard is under review by the Office of Information and Regulatory Affairs (OIRA) and can put nearly 40% of the U.S. population in areas of nonattainment.  Doing so would risk jobs and livelihoods by making it even more difficult to obtain permits for new factories, facilities and infrastructure to power economic growth. NFFS joined a joint letter written to Mr. Jeffrey Zients, Chief of Staff for the Biden Administration, urging the administration to maintain the existing fine particulate (PM 2.5) matter standards to ensure both continued environmental protection and economic growth on October 30, 2023. A copy of the letter can be found in this article published in the November 1st issue of The Crucible.
• Letter to Senate Committee on Finance Regarding Miscellaneous Tariff Bill
  

  The MTB temporarily removes or reduces tariffs on goods that are not made domestically or are not available in sufficient quantities in the United States. The last MTB expired after Dec. 2020 and since then, manufacturers and other businesses in the United States have been at a disadvantage compared to foreign competitors, paying $1.3 million per day in anti-competitive tariffs. The cosigned letter, addressed to the leaders of the Senate Committee on Finance and House Committee on Ways and Means, details the cost of inaction on the MTB since it is expired in December 2020, and highlights how passing the MTB will increase competitiveness, spur growth, and support the success of manufacturers, farmers, businesses, workers, consumers and communities throughout the U.S. A copy of the letter is provided in this article published in the November 29th issue of The Crucible.

Go to NFFS.org