MISSION
The North American Metals Council (NAMC) is a nonprofit corporation of member associations and companies engaged in metal production or metal use applications. NAMC members advocate on issues of strategic importance to the metals industry in a manner that complements rather than duplicates the work of other organizations. NAMC is structured and operated to maintain flexibility and allow for effective 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).
Membership in NAMC is open to companies that produce and/or use metals and minerals. NAMC is also open to trade associations that represent such companies. 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 or that have the potential to set a precedent that could impact metals in the future. 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.
NOTABLE PROJECTS/ACCOMPLISHMENTS
- Recognized as a key stakeholder group under the U.S. Environmental Protection Agency's (EPA) Negotiated Rulemaking Committee (NRC) that was set up per legislative mandate to identify options to limit inorganic byproducts reporting under the Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) rule. Although the NRC was not able to reach a consensus and has since disbanded, NAMC continues to monitor and will engage on this issue in the future.
- Continued engagement in TSCA implementation issues, with emphasis on the importance of relying on the EPA Framework for Metals Risk Assessment and the need for more flexible approaches to assessing conditions of use, particularly for metals and metal substances that are used extensively throughout today's society, including in agriculture, medicine, housing, infrastructure, transportation, telecommunications, and energy supply.
- Co-sponsored joint comments on EPA's proposed framework for conducting cumulative risk assessments under TSCA Section 6.
- Co-signed comments developed by the National Mining Association (NMA) regarding the pre-prioritization and consideration of existing metals and metals compounds (i.e., antimony, arsenic, cobalt, lead) for future prioritization under the Toxic Substances Control Act (TSCA).
- Engaged and networked with other trade associations to monitor ongoing TSCA implementation efforts.
- Submitted comments in support of the comments submitted by the Arsenic Science Task Force (ASTF) on EPA's Draft Staff Handbook for Developing Integrated Risk Information System (IRIS) Assessments (IRIS Handbook).
- Supported joint industry letter supporting the introduction of the "No Industrial Restrictions in Secret (NO IRIS)" Act to advocate for the use of the best available science and weight of the scientific evidence in EPA's IRIS program.
- Engaged with U.S. Occupational Safety and Health Administration and Health Canada to discuss concerns with a proposal to add endocrine disruption as a hazard classification under the United Nations (UN) Globally Harmonized Classification and Labeling System (GHS), highlighting metals-specific concerns.
- Organized an educational webinar for NAMC membership and guests on the Final TSCA Inventory Notification Rulemaking.
- Submitted scientific comments and advocacy positions on significant regulatory proposals or draft guidance materials, including:
- EPA Draft Technical Support Materials for the Final Freshwater Aquatic Life Selenium Criterion to address issues related to site-specific criteria;
- Agency for Toxic Substances and Disease Registry (ATSDR) draft Toxicological Profile for molybdenum;
- ATSDR draft Toxicological Profile for copper; and
- EPA Draft Updated Aquatic Life Ambient Water Quality Criteria for Aluminum in Freshwater.
- Supporting the work of metals trade associations that are NAMC members and engaged in a Cooperative Research and Development Agreement (CRADA) with EPA's Office of Water to develop collaboratively a comment approach to modeling to predict the bioavailability and toxicity of metals and to determine how bioavailability should be incorporated into a metals risk assessment for water quality.
METALS ASSESSMENT UNDER TSCA
Section 6(b)(2)(E) of amended TSCA requires that EPA rely on its 2007 Framework for Metals Risk Assessment (or successor document) in the prioritization or risk evaluation for metals or metal compounds. NAMC worked closely with EPA in the development of the Framework for Metals Risk Assessment document, which identifies the unique characteristics and attributes of metals and metal compounds that must be addressed to properly assess ecological and human health risks. Since publication of the EPA Framework for Metals Risk Assessment, NAMC has sponsored the publication of two manuscripts proposing updates to the Framework:
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