NFFS joins industry coalition in support of "No Industrial Restrictions in Secret" (No IRIS) Act

The Non-Ferrous Founders' Society (NFFS) has proudly joined a coalition of industry leaders in signing a support letter for the "No Industrial Restrictions in Secret (NO IRIS) Act of 2024"  (S. 3724/H.R. 7284). This important legislation, introduced by Senator Kennedy and Congressman Grothman, seeks to protect American manufacturing by ensuring that regulations are based on sound science.

The Environmental Protection Agency’s (EPA) Integrated Risk Information System (IRIS) program has increasingly been used to justify overly burdensome regulations on critical chemicals essential for everyday products. Despite Congress never having authorized IRIS, the EPA is poised to rely on IRIS assessments for several critical building block chemicals used in industries ranging from automotive manufacturing to semiconductor production to agriculture. This could lead to bans, unachievable standards, enforcement actions, and litigation, all of which threaten the viability of American manufacturing.

Recent examples of IRIS being used to support flawed regulations include:

• Formaldehyde Risk Evaluation: The EPA is on track to issue unscientific and legally questionable regulatory actions based on a flawed IRIS assessment under the Toxic Substances Control Act (TSCA). The proposed workplace standard is unreasonably low, even falling below background levels. This has drawn criticism from multiple peer review bodies, experts, and even members of the EPA’s own Science Advisory Committee on Chemicals (SACC).

• EPA Air Rules on Ethylene Oxide: These rules, which affect critical industries such as electric vehicles, semiconductor manufacturing, and health care, rely on an IRIS value for ethylene oxide that is 23,000 times lower than naturally occurring levels in the human body.

• Biden Administration DOJ Action: An IRIS value was used to justify emergency action seeking to shut down a manufacturing facility under Section 303 of the Clean Air Act

NFFS believes it is essential that regulations be based on the best available science. However, IRIS has consistently failed to meet this standard, often falling short in incorporating high-quality and relevant science and lacking transparency in its processes. By supporting the NO IRIS Act, NFFS is standing up for the future of American nonferrous foundries and ensuring that regulatory decisions are made on a solid scientific foundation.

We are committed to working alongside other industry leaders to build support for this critical legislation.

For more details, please refer to the American Chemistry Council’s press release on the EPA’s final IRIS assessment for formaldehyde.