Making the Case in Washington

Stephanie Salmon

On May 16, as part of the AFS Government Affairs Fly-In, metalcasters and members of the metalcasting supply chain crisscrossed Capitol Hill for meetings with more than 90 U.S. representatives and senators, as well as their legislative staff. They were there to discuss the importance of the U.S. metalcasting industry to the nation’s infrastructure network and national security.

The main concerns were OSHA’s crystalline silica rule, which has an enforcement deadline of June 23, the need for better infrastructure through the nation transportation networks and water systems, and funding to help fill a considerable talent shortage in the industry.

OSHA’s Crystalline Silica Rule
In March 2016, the Occupational Safety & Health Administration (OSHA) issued a far-reaching regulatory standard for occupational exposure to crystalline silica, with a new and significantly lower permissible exposure limit (PEL) for silica of 50 μg/m3.

OSHA’s silica rule also requires employers to implement a host of ancillary provisions, including engineering and work practice controls, develop a written exposure control plan, implement extensive housekeeping methods, offer medical exams, and train workers on silica.

Beginning June 23, general industry, including the metalcasting industry, must fully comply with the new silica standard. Metalcasters have been conducting extensive medical surveillance and industrial hygiene testing, and installing various engineering controls, including but not limited to retrofits, new ventilation systems and baghouses. On the housekeeping side, they have purchased high-powered vacuums and HEPA sweepers.

Despite these retrofits and installation of new controls, many foundries are still falling short of meeting the new lower PEL in several areas of their plants. Employers are required to exhaust all feasible engineering controls to reduce exposures below the PEL before implementation of work practice controls or respiratory protection. Engineering controls frequently need to be specially designed and constructed for the individual foundry.

Given the challenges and complexities of complying with OSHA’s new silica rulemaking, AFS believes an extension of the enforcement deadline is warranted. On May 16, AFS and the National Association of Manufacturers sent a letter to the U.S. Department of Labor requesting a six-month-delay of the silica rule from June 23 to December 23.

An enforcement delay would provide U.S. foundries and impacted industries additional time to work to get into compliance with the new silica rule. It would also provide OSHA time to finalize and distribute additional guidance materials to general industry, as well as make available for public review the compliance directive the agency is preparing for compliance officers on how to enforce the standard.

During the fly-in, metalcasters urged their lawmakers to sign onto a House and Senate letter requesting OSHA provide additional time of 180 days on the enforcement deadline for its silica rule.  The letters co-led by Reps. Bill Huizenga (R-Michigan) and Bradley Byrne (R-Alabama) in the House and co-led in the Senate by Senators Jim Inhofe (R-Oklahoma) and Todd Young (R-Indiana) were delivered to OSHA on May 24.

U.S. Infrastructure Network
America’s transportation network connects people and places, moves goods, drives the economy, and impacts quality of life and safety. However, America’s infrastructure is aging and in need of modernization.

Roadway congestion alone costs an additional 23 cents per mile to transport our goods.

Metalcasters play a critical role in the nation’s infrastructure network. More than 40% of all metal castings are dedicated to infrastructure.

AFS urged lawmakers to pass a comprehensive infrastructure package that includes:

Funding support for long-term projects by expanding and improving existing federal loan programs, creating a new loan guarantee program and expanding private activity bonds.

Streamlining the permitting process at the federal, state, and local level. It takes an average of five years to complete an environmental impact statement, a federal requirement for many projects.

Ensuring the use of American-made materials, specifically, extending the Buy America provisions to all federal infrastructure programs.

U.S. Water Infrastructure
Nationwide, a large proportion of the water infrastructure–including water and wastewater treatment systems, pipes, locks, and dams—is approaching, or has already reached, the end of its useful life. Most of the buried drinking water infrastructure was built 75–100 years ago or more, and as much as 25–30% of the treated water that goes into distribution systems leaks into the ground.

The American Society of Civil Engineers gave the U.S. drinking water systems, dams, and levees a D grade in its 2017 report card on the nation’s infrastructure.

Over the next 25 years, investment needs for buried drinking water infrastructure will exceed $1 trillion nationwide, according to the American Water Works Association.

U.S. metalcasters produce components for our water infrastructure systems that include pipes, pumps, valves, water meters, manhole covers, fire hydrants, drainage grates and other key water infrastructure components. The Environmental Protection Agency’s (EPA) Clean Water and Drinking Water State Revolving Funds, and the Water Infrastructure Finance and Innovation Act (WIFIA), provide key funding to help states and communities meet critical and costly water challenges.

Of most interest to metalcasters are the following key pieces of legislation:

Water Infrastructure Finance and Innovation Reauthorization Act (WIFIA) (H.R. 4492/S. 2329)—This bipartisan legislation would re-authorize and boost funding for the WIFIA program, which provides long-term, low-cost credit assistance for financing large water infrastructure projects. It would increase WIFIA’s FY19 authorization from $45 million to $90 million. WIFIA leverages funding at a ratio of at least 50:1.

State Revolving Fund (SRF) loan program—The SRF program for drinking water systems has provided much-needed support, primarily for small- to medium-sized projects or communities, since 1996. AFS is seeking legislation that will double funding for both the drinking water and clean water SRF programs for FY2019.

Private Activity Bonds (PABS) for water/wastewater infrastructure—PABs are a form of tax-exempt financing for state and municipal governments that want to collaborate with private entities to meet public needs. Removing state volume caps would free up billions of private capital dollars for water infrastructure investment.

Municipal Infrastructure Savings and Transparency Act (H.R. 5310)—This legislation would impose new federal mandates on state and local governments making infrastructure improvements. AFS opposes legislation like H.R. 5310, because it is inconsistent with the goal of encouraging and supporting those closest to the problem to determine the best solutions. AFS argues one-size-fits-all mandates increase burdens and costs on local utilities without regard for the diverse water and wastewater infrastructure needs of local communities, which must evaluate numerous factors when considering the proper design and materials for their communities and water projects.

U.S. Metalcasters Face Workforce Challenges
The U.S. manufacturing sector currently has more than 350,000 unfilled skilled jobs, and millions of manufacturing employees are expected to retire in the next few years.

Today, more than 80% of metalcasters report a talent shortage in the industry—from production level, maintenance and technician positions, to machinists, electricians, patternmakers, and foundry engineers. Over the next decade, nearly 3.5 million manufacturing jobs will likely need to be filled. To compete globally, U.S. metalcasters require high-quality workers, as well as a strong technical workforce.

At the Fly-In, members of the metalcasting industry discussed the following items with their Congressional officers:

Carl D. Perkins Career and Technical Education Act—AFS asked legislators to increase funding for the Perkins State Grant program (Title I) in the FY19 Labor HHS appropriations bill. Perkins provides the principal source of federal support to strengthen the career and technical education (CTE) at secondary and postsecondary institutions.

Strengthening Career and Technical Education Act (H.R. 2353)—This legislation reauthorizes Perkins loans, and passed the House unanimously in June 2017.

Jumpstart Our Businesses by Supporting Students Act (JOBS Act) (S. 206)—This bipartisan bill would expand the eligibility of Pell grants to include students enrolled in short-term skills/job training programs that are at least eight weeks long and lead to industry-based credentials.  

Click here to see this story as it appears in the June 2018 issue of Modern Casting