PMPA Comments on EPA's Proposed "Clarification" of TRI Article Exemption
Monday July 26, 2010
We recently attended a meeting with OMB and EPA officials regarding EPA’s proposed “Clarification” of the Article exemption under TRI 313 Reporting. We were joined with representatives of roughly 14 other industry spokespeople at this meeting.
Many precision machining shops make use of the article exemption in some form, so any changes to the definition would require all precision manufacturing companies to reassess their need to report under the new clarification.
EPA’s own estimates of reporting burden go to 51.3 hours to collect all the needed data, evaluate your compliance to the rule, do the calculations and report.
PMPA provided an analysis showing that the burden on just the precision machining industry in the US would be of the order of $3.5 million, fabricated metal industry, $66 million, and over $209 million for the entire 33 NAICS code including precision machining, fabricated metal, and machinery manufacture.
The fact that this impact falls mainly on our small businesses was also made. To see our letter, click on the link below (Statement of PMPA in regards to TRI).