Three points you should know about the EPA’s proposed TRI ‘Clarification’
- It underestimates industry burden. It would cost our Precision Machining Industry on the order of $3,534,104 in preparation, collection of data, analysis and reporting costs.
- This impact falls mainly on our small businesses – 54 % of US Precision Machining shops employ less than 20 employees.
- The “Clarification” does not provide a positive impact on public health and safety, and it wil llikely foster over reporting, double counting of “releases” and otherwise mislead the public.
We recently attended a meeting with the Office of Management and Budget (OMB) and Environmental Protection Agency (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.
Read our submission to OMB and EPA.
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. In the US, that means 3,364 perecision machining establishments would need to spend, according to the EPA’s own estimates, 51.3 manhours to properly evaluate and report.
While the EPA’s federal register comments indicate that only the treated lumber industry would be affected, representatives from a wide range of industries were in attendance to show how the proposal would eliminate the Article Exemption for their products.
PMPA was there to show how, if the Article Exemption were lost, the reporting burden for our industry would be orders of magnitude higher than the EPA’s estimate of $13,877.
$13,877!
That’s right. EPA thought that the TOTAL INDUSTRY Reporting Burden for this “Clarification’ would be no more than $13,877.
Using the 2007 Survey of Manufactures data from the U.S.Census, We were able to show that the cost of evaluating our new reporting status as an industry would be at least $3,534,104. That is just for Precision Machining Shops.
For Fabricated Metals, which includes Precision Machining, the burden jumps to $66,235, 899. And for the entire 33 NAICS code, including Precision Machining, Fabricated Metals, and Machinery Manufacture, the impact is over $209 Million Dollars.
EPA’s estimate of Reporting burden for NAICS 33XXXX underestimates by a multiple factor of 15108.83 times.
PMPA’s mission and vision charges us to provide resources that “advance and sustain” member companies within the Precision Machining Industry.
That’s why we went to Washington. To save you and 3,363 of your peers from a “clarification” that would have burdened the industry to the the tune of about $3,534,104. Or US manufacturers in NAICS 33 about $209 million.
EPA would better serve its mission by clearly defining what is a release, and exempting legitimately recycled materials such as scrap metals from TRI reporting.
That’s is a change we could support.
Read our submission to OMB and EPA.
