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 works to complement and coordinate rather than duplicate the work of other organizations. NAMC is structured in a way that maintains flexibility and allows for rapid mobilization to address key issues and initiatives as they arise. 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).
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. Over the years, NAMC has been effective in advocating positions on its members’ behalf on a variety of matters that are important to the metals community; a few are noted below.
RECENT PROJECTS/ ACCOMPLISHMENTS
- NAMC successfully advocated for the U.S. Environmental Protection Agency (EPA) to indicate its support for the draft Organization for Economic Cooperation and Development (OECD) “Guidance On The Incorporation Of Bioavailability Concepts For Assessing The Chemical Ecological Risk And/Or Environmental Quality Standard Setting Of Metals And Inorganic Metal Compounds.”
- NAMC submitted comments on numerous significant regulatory and scientific issues, including:
- Comments to the U.S. Department of Energy (DOE) in response to its request for information (RFI) on rare earth elements and other materials used in energy technologies;
- Comments in support of EPA’s Draft Technical Support Document: Recommended Estimates for Missing Water Quality Parameters for Application in EPA’s Biotic Ligand Model (BLM);
- Comments on EPA’s Draft Guidelines for Human Exposure Assessment;
- Comments to EPA on the Draft Aquatic Life Ambient Estuarine/Marine Water Quality Criteria for Copper; and
- Comments to the Oregon Department of Environmental Quality (DEQ) on its proposed rulemaking to establish aquatic life water quality standards for copper.
- NAMC successfully advocated for EPA to continue to announce draft Integrated Risk Information System (IRIS) assessments through the Federal Register.
- NAMC sent a letter to the U.S. Occupational Safety and Health Administration (OSHA) requesting that the U.S. delegation to the United Nations’ (UN) Subcommittee of Experts on the Globally Harmonized System for Classification and Labelling (GHS) support a proposal from the International Council on Mining and Metals (ICMM) that would revise subsection 14.7 of the GHS guidance for compiling a safety data sheet (SDS) to allow for the inclusion of information related to International Maritime Organization (IMO) classifications, such as hazardous to marine environment (HME) or materials hazardous only in bulk (MHB).
- Organized a webinar for members on the 2016 Chemical Data Reporting (CDR) rule requirements.
- Other Activities:
- 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.
- NAMC continues to advocate for the use of EPA’s Metals Risk Assessment Framework, a science-based document that NAMC played a role in developing, with comments on successive drafts of the framework, active participation in Science Advisory Board reviews, and participation in workshops, peer review efforts, and expert consultations.
- NAMC hosts information webinars for members and guests, such as the January 6, 2015, Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) and Globally Harmonized System of Classification and Labeling of Chemicals (GHS) seminar for the metals industry in Washington, D.C., where more than 70 companies participated.
- NAMC tracks ongoing work with OSHA on the incorporation of elements of GHS rules for substance classification and labeling into OSHA’s Hazard Communication Standard.
- NAMC continues to engage with U.S. government officials from the State Department, Commerce Department, and Office of the U.S. Trade Representative to discuss issues of concern to the metals sector within international sectors, such as REACH, the Strategic Approach to International Chemicals Management (SAICM) , and the Convention on Long-Range Transboundary Air Pollution (LRTAP).
- NAMC will continue to coordinate and engage with other stakeholders on state issues, advocating that metals not be classified as persistent, bioaccumulative, and toxic (PBT) chemicals.
- NAMC continuously alerts members to new issues of importance for individual metals and for metals generically.