Dodd Frank Section 1502 Conflict Minerals Guidance for Machine Shops

March 20, 2013

PMPA staff has prepared a Conflict Minerals compliance guide  for our members based on our analysis and understanding of the SEC’s final rule.

That’s 356 pages worth of time we won’t be getting back- but that we can save you!

Saving you the pain...

Saving you the pain…

Our two page summary provides

  • a link to the final rule;
  • an overview of the potential impact of the rule;
  • explains the SEC’s determination of what constitutes “Conflict Minerals” as applies to our precision machining shops;
  • clarifies the “necessary to production question” that concerns many people.  (If the conflict minerals are in my shop’s tools, machinery, or computers, do they need to be reported?)

In addition to identifying the 4 focus minerals that are encountered in our industry, our report provides 5 questions to help you make sense of  and formulate your reply to each job and request for documentation from your customers for Conflict Mineral Status.

Finally, our document provides both the means to determine and suggested language to warrant that your product is “DRC Conflict Free” to your customer.

Effective associating through PMPA means that our members get a clear plain English tool they can use document to make sense of their obligations under Dodd Frank.  And guidance on how to respond and educate your customer.

Where do you go to get sensemaking on newly emerging regulatory requirements?

PMPA members know that we provide them with REGULATORY ASSURANCE.

PMPA provides assurance  to you in the high stakes world of regulatory compliance.

PMPA provides assurance to you in the high stakes world of regulatory compliance.

Our diligence on identifying regulatory issues and sensemaking on regulations help PMPA members assure compliance and avoid draconian penalties. And we provide tools they can use to respond effectively and confidently minimizing the impact and burden their shop.

That is Effective Associating!

Where do you go to get sensemaking on newly emerging regulatory requirements?

Not a PMPA member? Call Jeff Remaley 440 526 0300

Highwire


Disaster Recovery- Effective Associating

November 1, 2012

The current perfect storm- whether you call it Hurricane Sandy, Frankenstorm, or “OH S**t what am I gonna do now?”-  provides a compelling testimony to the strengths of effective associating. Networking.

At PMPA today, networking  means   “Helping match shops with open capacity and similar capabilities to shops needing an assist to keep shipments on time due to a natural  or other disaster.”

That’s an “invaluable when you need it,” kind of networking.

Yes, networking can take place at a conference but…

The Precision Machined Products Association (PMPA) created our Disaster Recovery Plan for PMPA members several years ago.

You can find it on our website at Disaster Recovery Plan

We prepared it to  have a structure for providing assistance when a member shop had a fire, storm damage, or lost a key piece of equipment.

We are fortunate to have not had to employ it more than a handful of times.

Yesterday, I posted a notice about where to find the plan, and requesting shops who were available to provide assistance via open capacity or capability  to notify PMPA so we could put them on our  list of candidate shops.

In less than an hour a  couple dozen shops had sent details of their capability, open capacity, materials worked with, and quality system credentials  so that we could prepare our candidate list of shops ready willing and able to assist disaster stricken fellow members.

Many people hear the word “networking” and think of golf, or conversations at conferences, or at local meetings.

At PMPA networking is not just a round of golf…

But networking can also be a more substantial, value added, support function at the time when you need it most- when your shop is in the midst of “disaster” and you are torn between the needs of your shop and the needs of your customers.

PMPA’s Business Disaster Recovery Plan for PMPA members is the highest and best form of networking- sharing our strengths to support our customers and fellow members at the time that they need support the most.

Networking. It’s not just a casual synonym for friendly chat or connecting.

In times like this, networking is about making a profound difference. Helping a fellow shop meet their obligations. Protecting and serving the interests of our mutual customers.

PMPA members are stepping up with their offers to assist.

PMPA is  ‘all about’  networking.

Networking as in “Helping match shops with open capacity and similar capabilities to shops needing an assist to keep shipments on time due to a natural  or other disaster.”

We call that effective associating.

What’s your shop’s safety net? Where can you turn for support when the waters rise or a fire shuts you down? 

How do you answer your customers’ queries about your disaster recovery plan?


Burdensome Regulations- Letter to House Oversight and Government Reform Committee Chair Darrell Issa

June 27, 2012

We sent our letter to attention of Chairman Darrell Issa…

Earlier this month,  Precision Machined Products Association (PMPA) submitted a  joint letter with NTMA and PMA in response to a request by House Oversight and Government Reform Committee Chair Darrell Issa for examples of ill-conceived regulations and rules interpretations and their impact on metalworking manufacturers.

The letter stated, “The first week of May 2012, the federal government issued 77 new final rules and regulations and proposed 40 new rules. As of May 25, 2012, the year-to-date total for new federal rules and regulations issued was 1,506, filling 31,432 pages. Of these new rules, the government classified 292 as having a significant impact on small businesses. Companies like our members simply lack the resources, financial or personnel, to sort through the thousands of pages of new regulations each year. Compounding this challenge is a lack of knowledge of industry process by regulators who are not familiar with manufacturing and therefore often issue ineffective rules with unintended consequences.”

The letter provided examples of existing and proposed regulations and rules interpretations that negatively impact metalworking manufacturers, reduce global competitiveness and restrict the ability to hire employees and invest in facilities. Examples included the EPA’s TRI Article Exemption Rule, Nickel Rule and Metalworking Financial Responsibility Requirements Rule; OSHA’s interpretation of lockout guidelines, arc flash requirements and guidance memo indicating that safety incentive programs may potentially be a discriminatory violation against disciplined employees and may discourage safety violation reporting; and the SEC’s conflict minerals rule. Read the full letter.

You have more than enough on your plate to say grace over without having to battle the bureacrats and regulators and their ill conceived burdensome regulations.  PMPA’s regulatory efforts are just one way of  “effective associating” that can help you and your company in today’s hostile regulatory environment.


Regulatory Reform- EPA Article Exemption “Clarification” Withdrawn

June 22, 2011

 On June 17th, at the request of the US Environmental Protection Agency, the Office of Management & Budget removed from its list of Submissions Under Review (http://www.reginfo.gov/public/do/eoDetails?rrid=119517 ) the EPA proposed final “Toxics Release Inventory (TRI) Articles Exemption Clarification Rule.”

The proposed rule would have eliminated the articles exemption under TRI and required manufacturers to report releases from finished goods in storage.

Finished goods in storage!

 Here’s the rest of the story:

Last July PMPA attended a meeting in Washington D.C. with OMB and EPA over a proposed EPA “Clarification” regarding the article exemption in TRI.

We were joined at that meeting by a number of other involved parties with similar concerns. The meeting was hosted by Jeff Miller of the Treated Wood Council.

We opposed the change and challenged the EPA’s estimate of Paperwork Burden, demonstrated impact on smaller businesses, and made other technical points.

Paperwork burden and manhours to prepare were just the tip of the iceberg.

You can see our Business Intelligence on this issue here .

The EPA’s proposed  change in the “clarification” could have made finished precision machined products with rust preventives subject to TRI release reporting.

At EPA’s request, this submission was removed from review.

We are pleased that our attention to this regulatory issue  with other affected industries has resulted in its withdrawal at the current time. Our position was that the EPA cannot change the TRI rule without formal rulemaking.    Members of Congress have echoed that same concern.   

EPA may ultimately decide to initiate that rulemaking process.  

We do not know exactly why EPA withdrew the proposed rule, nor do we know EPA’s next steps.  

There is nothing transparent about regulation of  small business in Washington D.C.

But for now, as a result of our “effective associating”  and engagement with the federal agencies involved, this ill-considered change to TRI has been withdrawn.

 We will continue to monitor this issue and keep you informed of any developments.

Paperwork Photo :


Wish I Was There!

April 17, 2011

Sometimes, you just have to leave it in the good hands of your trusted colleagues.

If I was there this year, my smile would be even wider.

I was on the schedule for this year’s PMPA National Technical Conference and Precision Machining Technology Show being held in Columbus now through Thursday. I had prepared a couple of presentations and was really looking forward to reconnecting with the people who make things- You!

Sometimes however, Life has other plans.

I’m happy to know that Bob Drab, a colleague of many years and THE product specialist on stainless at Schmolz + Bickenbach will be presenting my program on Material Sensemaking- Understanding Foreign Grade Designations. And that one of my fellow staff directors will be giving my presentation giving you a behind the scenes look at the TOOLS YOU CAN USE on PMPA’s website.

Precision Machining companies belong to the PMPA because they know the benefits of collaborating to solve problems. To share resources that perhaps each one needs but cannot afford on their own. To know that they have a network of knowledgeable industry professionals available to back them up when they run into a problem they haven’t seen before.

Just as companies in the PMPA back each other up by sharing resources, knowledge and solutions to solved problems, I have learned that staff and colleagues do the same for each other when the need arises.

I call this EFFECTIVE ASSOCIATING.

I’d have given anything to be there with my ‘INDUSTRY’ in Columbus this week.  To see you. To listen to your ideas, answer your questions, hear your concerns, see new processes, meet old friends.

MAKE NEW FRIENDS.

But it wasn’t in the cards.

Why, I’d rather  chauffeur Bob Drab around on a bicycle… than miss this event.

Id do about anything to be at PMTS

Sorry I’m not able to be there. While you’re there, say”Hi” for me to Bob Drab,  and my staff colleagues Monte, Rob, Mike, and Carla.

And please, somebody take some photos!


OSHA WITHDRAWS REINTERPRETATION OF “NOISE” PROPOSAL

January 19, 2011

The U.S. Department of Labor’s Occupational Safety and Health Administration today announced that it is withdrawing its proposed interpretation titled “Interpretation of OSHA’s Provisions for Feasible Administrative or Engineering Controls of Occupational Noise.”  The interpretation would have clarified the term “feasible administrative or engineering controls” as used in OSHA’s noise standard.  The proposed interpretation was published in the Federal Register on Oct. 19, 2010.

PMPA alerted the industry  and other metalworking associations to this proposed reinterpretation when it was first published in the Federal Register. We wrote requesting an extension for comments and fact finding. We have been gathering data to establish the cost burden of the proposal on the small manufacturing businesses that we serve.

Thanks to all who joined with PMPA, our members who commented, and other metalworking associations who also commented and made their concerns known.

As a result of effective associating, this ill-conceived proposal has been withdrawn.

You can read the OSHA Announcement here.

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