Government Affairs & Advocacy
Defending the foundry industry's concerns & interests
For over 70 years, NFFS has served as the voice for non-ferrous foundries. The NFFS staff and Government Affairs Committee actively monitor new legislative and regulatory developments in Washington, as well as at the regional and state levels, and effectively represents the interests of non-ferrous foundries. All U.S. non-ferrous foundries have at some point benefited from the Society's efforts to protect the industry from misguided or overly burdensome regulations.
In past years, the Society filed comments on the proposed Silica Rule, commented on the NFPA’s revision to its guidance standard on combustible dust, submitted recommendations regarding EPA’s planned implementation of the Safe Drinking Water Act amendments that reduced the permissible lead content limit, and met with representatives of the Office of Management & Budget concerning revisions to the copper benchmarks in the proposed EPA Stormwater Multi-Sector General Permit. In 2016, NFFS was the only trade association to advocate against the OSHA Beryllium Rule on behalf of general industry. You can have confidence that NFFS will continue to defend the concerns and interests of your foundry when government regulations affect our industry.
NFFS Advocacy Successes
In 2009, the NFFS filed comments with the U.S. EPA Office of Air Quality Planning and Standards regarding the proposed Foundry Area Source Rule. As a direct result of NFFS involvement and advocacy, aluminum foundries and copper foundries pouring under 6,000 tons per year were exempted from having to conduct annual stack tests of their air emissions, which can cost in excess of $10,000/year or more.
In 2011, the EPA reopened the Secondary Aluminum MACT rule and express concern that the clean charge exclusion is no longer appropriate for aluminum foundries. NFFS, the only metal casting association named as a Small Enterprise Representative in the reconsideration of the rule, negates the EPA's concern by reminding them that aluminum foundries are not secondary aluminum production facilities according to the 2009 Foundry Area Source Rule and are thereby are exempt from its requirements, allowing aluminum foundries remelt internal scrap instead of being required to dispose of it as a waste.
The NFFS Government Affairs Committee regularly defends our industry's interests with an active and involved communication strategy, speaking to regulators and authorities as required to ensure our collective voices are heard on both the State and the Federal level. Below is a partial listing of just some of the issues on which your GAC has advocated to represent non-ferrous foundries:
- H.R. 5376, the “Inflation Reduction Act” reconciliation legislation (regarding accelerated depreciation)
- H.R. 2193 Asuncion Valdivia Heat Illness and Fatality Prevention Act (congressional heat exposure rule)
- EBIT vs EBITDA tax interest deductions (2021)
- Miscellaneous Tarriff Bill (2020) - US Commerce Department
- "Once in Always In" rule for General Provisions of the National Emission Standards for Hazardous Air Pollutants (NESHAP)
- Regulation and Regulatory Reform Effort (2020), House Committee on Oversight and Reform
- Strengthening America's Supply Chain - supply chain resilience subtitle of the House-passed America COMPETES Act
- OSHA COVID-19 Emergency Temporary Standard - US Dept of Labor/OSHA 2021
Government Affairs Committee
The NFFS Government Affairs Committee meets on the last Thursday of each month at 2 p.m. ET. For additional information or to participate, please contact jerrod@nffs.org.