NAMC MISSION
NAMC provides leadership and plays an advocacy role on select issues of strategic importance to the metals industry. NAMC's efforts concentrate on multi-metals issues where a cohesive industry voice is beneficial. NAMC's approach is grounded in sound science and is supported by active engagement with the leadership of key national and international organizations (regulatory and non-regulatory).
A primary advocacy objective for NAMC is to highlight the unique risk assessment issues presented by metals and to ensure that those regulatory agencies engaged in risk assessment appropriately address those unique issues. In that regard, NAMC worked closely with the U.S. Environmental Protection Agency in the development of the “Framework for Metals Risk Assessment,” a science-based document that describes basic principles that address the special attributes and behaviors of metals and metal compounds to be considered when assessing their human health and ecological risks. NAMC played a key role in the development of the Framework, including the submission of comments on successive drafts of the framework, active participation in Science Advisory Board reviews, and participation in workshops, peer review efforts, and expert consultations.
More information on the EPA framework document can be accessed here.
KEY NAMC ISSUES/PROJECTS
NAMC’s membership is diverse, as is the range of substantive issues on which NAMC engages. We actively monitor and/or engage in advocacy with respect to programs affecting many metals. As a result, NAMC’s ability to share intelligence on regulatory initiatives timely and efficiently is unparalleled. Below is a brief summary of advocacy and/or information sharing activities in which NAMC has been engaged.
On an on-going basis, NAMC prepares and circulates electronically to members a comprehensive monthly update on North American and international regulatory, science, and legislative developments pertinent to member company interests. It continuously alerts members to new issues of importance for individual metals and for metals generically.
NAMC is actively monitoring Congressional debate on TSCA reform, including the likelihood of hearings, and preparing communications that identify metal’s specialized issues that must be considered in legislative proposals.
NAMC is engaged in stakeholder dialogues during the ongoing negotiation activities for the Mercury Programs at the United Nations Environment Programme (UNEP) to ensure mining for other metals is not adversely impacted.
NAMC has engaged with U.S. State, Commerce, and Transportation Departments to assist the U.S. in developing a position on the Strategic Approach to International Chemicals Management (SAICM). NAMC successfully advocated for removal of the term “heavy metals” and greater emphasis on scientifically-based determinations. NAMC continues to monitor SAICM developments and works to ensure its members’ views are reflected in the U.S. position.
NAMC submitted comments and provided testimony to the Occupational Safety and Health Administration (OSHA) on the proposed incorporation of elements of GHS rules for substance classification and labeling into OSHA’s Hazard Communication Standard. OSHA is expected to issue a proposed rulemaking to implement GHS in 2011, which will have a significant impact to the metals industry. NAMC will actively engage in advocacy, as well as training and education outreach for its membership.
NAMC members participate in briefings on the Convention on Long-range Transboundary Air Pollution (LRTAP) Heavy Metals Protocol and provided input to the U.S. government delegation on issues of interest, as well as coordinating with international metals industry representatives to LRTAP meetings.
NAMC provided comments to Washington State’s Department of Ecology successfully urging on scientific grounds that metals not be classified as persistent, bioaccumulative, and toxic (PBT) chemicals.
NAMC has been involved in advocacy activities in states where efforts are underway to develop green chemistry/toxic chemical lists, such as Minnesota and California.
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