The North American Metals Council (NAMC) is an unincorporated not-for-profit group of 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 to maintain flexibility and allow 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).
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 potentially 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.
RECENT 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.
- Engaged and networked with other trade associations to monitor ongoing TSCA implementation efforts.
- Coordinated with other industry coalition members in monitoring the status of and developing strategy for addressing Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 108(b) financial assurance rulemaking.
- 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; and
- EPA Draft Updated Aquatic Life Ambient Water Quality Criteria for Aluminum in Freshwater.
Metal 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 assess properly ecological and human health risks.