2017 Regulatory Advocacy Agenda
You can also view ILMA's Legislative Advocacy Agenda here.
INDUSTRY SPECIFIC ISSUES - Because these issues are specific to lubricant manufacturers, ILMA will lead advocacy initiatives.
- NCWM Issues
a) Development of regulations related to labeling of Automatic Transmission Fluid.
ILMA Priorities: Secure National Conference on Weights and Measures’ (NCWM) adoption of proposed revisions to Handbook 130 on labeling and performance claims for transmission fluids, including multi-vehicle ATFs. Encourage California Department of Food & Agriculture to develop implementing regulations for A.B. 808 that do not restrict the transmission fluid market in California.
b) Development of regulations banning certain motor oils considered to be obsolete.
ILMA Priorities: Move ILMA’s proposed revisions through NCWM’s process for amending Handbook 130 to eliminate obsolete oils from the retail market for on-highway vehicles, while recognizing certain exceptions for purpose-built and other engine oils. Continue to participate in the rulemaking process with California’s Department of Food & Agriculture’s Division of Management Standards (DMS) on its implementation of A.B. 808.
- EPA Ban of MCCPs and LCCPs
ILMA Priorities: Continue to work independently and with the coalition of trade associations for the appropriate regulatory review of MCCPs and LCCPs. Advocate for independent, third-party peer review and appropriate treatment of the substances as “existing chemicals” under TSCA Section 6. If the Agency still has concerns after the appropriate procedures are followed, work collaboratively to determine an appropriate risk management resolution that allows for continued use of MCCPs and LCCPs while addressing the Agency’s concerns.
TIER 1 ISSUE - This issue affects a broader segment of the business community, but was ranked as “Top Priority” by ILMA Members.
- OSHA / Labor Issues
ILMA Priorities: Continue to work with OSHA on GHS compliance issues and advocate improvements to HCS 2012 that effectively conveys potential chemical risks to employees while reducing the ILMA member’s compliance burden. Support legislation and regulation to restore the time-tested balance between labor unions and employers at the Department of Labor and National Labor Relations Board. Support efforts to prevent OSHA’s attempts to remove “unexpected” from its lock-out/tag-out rule. Support Congressional action to undue “clarification” of employer’s obligation to make and maintain accurate records to ensure the OSH Act’s six-month limitation period remains intact. Support legal challenges and Congressional action on electronic injury/illness reporting rule.
TIER 2 ISSUE - This issue affects the business community as a whole, and was ranked as “Very Important” by ILMA members.
- EPA Amendments to SPCC
ILMA Priorities: Monitor and participate in EPA rulemaking that expands SPCC rule to “hazardous substance” ASTs, and facilitate meetings between the membership and the Agency during the rulemaking process as appropriate.