In such a tumultuous political era, it can often be difficult to cut through the noise and understand how the actions taken by lawmakers and regulators in Washington, D.C. and state capitals matter to your bottom line and shop floor. As your industry association, it is ACMA’s job to be your eyes, ears and voice on the litany of issues facing the industry. ACMA’s Government Affairs team and our member volunteers work diligently to navigate policy challenges and advance the common interests of every company in our industry.
ACMA’s advocacy programs protect the ability of composites manufacturers to employ the materials and processes they need to supply products for demanding end uses and promote public policies favoring the use of composite products in major markets. The association provides its members guidance and tools for cost-effective regulatory compliance. With the weight of a united industry behind us, ACMA also works aggressively to use legislation to create new opportunities for composites in key underdeveloped sectors.
With this backdrop in mind, let’s review the state of play of some key regulatory/compliance and market growth initiatives.
Communicating with Customers
OSHA’s Hazard Communication Standard requires manufacturers to inform customers if the normal anticipated use of products generates combustible dust. This is an important topic for any manufacturer of products that are polished, sanded, cut, ground or otherwise mechanically worked by downstream customers or end users. ACMA’s guidance helps composites manufacturers prepare safety data sheets that can be used to inform customers of combustible dust hazards and comply with OSHA’s regulation and policy.
ACMA’s research suggests the majority of composite products are exempt from the Prop 65 regulations requiring toxicity warnings for customers and end users in California, but the exemption is product-specific and can be formally established only by taking an enforcement action to court. To best manage compliance uncertainty and minimize the risk of expensive enforcement suits, composites manufacturers can use ACMA’s guidance and tools to prepare Prop 65 mitigation plans for their products sold into California. You can access these tools on the ACMA Education Hub – www.acmaeducationhub.org/products/1079/understanding-prop-65.
EPA and state agencies regulate releases to the atmosphere of styrene, methyl methacrylate (MMA) and grinding dust, among other substances found in composites manufacturing shops. Manufacturers need reliable estimates of the emissions of these substances from their operations before they can apply for permits or comply with reporting and emission control requirements. ACMA’s Unified Emission Factors is a widely accepted tool for estimating styrene and MMA emissions, and will soon include emission estimation factors for cast polymer operations. ACMA’s recently issued guidance and workbook for particulate matter emissions was peer reviewed by a major state regulatory agency. You can access the guidance and workbook on the ACMA Education Hub – www.acmaeducationhub.org/products/1088/estimating-particulate-matter-emissions.