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ACMA Upfront
By Tom Dobbins
The Constant Threat: ACMA Protects Members from Regulatory Pitfalls
I have been reminded by recent events—plant inspections by regulatory
officials—how vital success on environmental issues is for the composites
industry. Competition within the industry and with other more conventional materials
is fierce. Companies are constantly looking for ways to cut costs. Yet, one
major change in the regulation of emissions at the federal, state or local level
could undo years worth of cost cutting, tip the competitive balance towards
other materials, and therefore shrink markets and decrease profitability.
This constant threat is one of several “glues” that hold the industry
together and make membership in ACMA so valuable. It is only together, with
a collective focus, that the industry can protect its investments, markets,
and profits in a way that no single company could hope to achieve—even
with the same level of resources. ACMA’s ability to speak for the entire
industry gives it a power that extends beyond the message.
On the federal level, ACMA continues to maintain an excellent working relationship
with the U.S. Environmental Protection Agency. The extensive knowledge of our
volunteers and staff on emissions has made us a trusted partner with the agency.
The extent of that partnership was recently highlighted in our working with
EPA on ACMA’s Unified Emissions Factors or UEF. As you know, ACMA has
worked for 10 years to develop the UEF. The EPA trusts us to maintain the UEF
and to educate our members on its use.
In testing over the summer, ACMA learned that certain resins and processes
were producing higher emissions than those predicted by the UEF. Our first action
was to disclose the data to EPA with a solemn commitment to expand the UEF,
to predict accurately these materials and processes. Rather than swooping down
with new enforcement on the industry as I have seen them do with other industries,
the EPA responded with patience. I am pleased to report that ACMA kept its side
of the bargain when the Board of Directors voted in St. Louis last month to
commit $250,000 per year for at least the next three years to do the testing
necessary to expand the UEF so that it can continue to be an accurate predictor
of emissions.
ACMA’s commitment to this area is not limited to working with regulatory
agencies. It also includes educating its members. I encourage ACMA members to
visit our website to learn the latest developments on UEF and emissions issues.
In addition, we anticipate another of our national conference call briefings
on MACT in the spring.
Unfortunately, we don’t contend with regulatory issues only at the national
level. The states have their own environmental regulations and enforcement agencies.
As we have learned, bad policies travel fast. A regulation in one jurisdiction
can be adopted in other areas of the country that are trying to stay abreast
of the latest regulatory information. That is why ACMA will act aggressively
for, or against, state and local regulations that can set precedent. This happened
recently in Ohio where state regulators proposed standards that could have forced
compression molders in the state to install pollution control equipment—a
very costly proposition. Swift action, respected expertise, and compelling arguments
led to the proposed regulations being rescinded.
In spite of these successes there are still significant threats that remain.
EPA’s Region 5 enforcement branch is looking at emissions from compounding.
Like dealing with any big organization, our positive relationship with the regulators
in EPA does not assist us in dealing with enforcement. We must start all over
with our efforts to educate them on how to accurately measure emissions.
None of these accomplishments come easy or cheap. It starts with the committed
volunteer leadership of our Government Affairs and Technical Committees. The
members of those committees collectively spend hundreds of hours a year working
on these issues for the benefit of the industry. Every other member of ACMA
also contributes to our success in governmental and regulatory affairs through
their dues. A significant part of ACMA’s budget goes to the testing, staff,
lawyers, and expert environmental consultants who deliver success on these issues
year after year.
These issues could be considered relatively minor compared to those needed
to combat a hostile legislative initiative or regulatory changes that would
certainly come in the wake of an environmental catastrophe. It is critical that
all manufactures, distributors, and suppliers are members of ACMA so that the
composites industry will have the resources available to protect our markets,
investments, and the jobs we provide throughout the country.
Tom Dobbins
Chief Staff Executive
703.525.0511; tdobbins@acmanet.org
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