AFS Agenda for a Strong Metalcasting Economy

AFS is the only association working full-time to advocate for a positive business climate for the $33 billion Metalcasting economy. Metalcasting is essential to manufacturing, national defense and job creation. To help AFS advance this agenda through Corporate Membership, call Ben Yates at (847) 824-0181 X 205.
 

Key Issues:

Tax Policy

AFS aggressively advocates for policies that encourage capital investment, and restore simplicity and certainty to the U.S. metalcasting industry.  AFS supported the successful 2017 effort by Congress and the President to reform the tax system. The association will continue to work with policymakers as other tax issues arise, drawing on the following principles:

 

AFS supports the following key tax principles:

  • Lower Tax Rates - Lower tax rates, that are more competitive with other industrialized countries, should apply to companies of all sizes no matter how they are organized, including corporations and pass-through entities.
  • Full Expensing for Capital Equipment - AFS supports retaining a robust capital cost-recovery system such as accelerated depreciation and full expensing, to drive new investments in foundries.
  • Strong & Permanent Research and Development (R&D) – AFS supports maintaining a permanent R&D incentive to keep metalcasters performing R&D and boost U.S. innovation.
  • Permanent Estate Tax Repeal – The association supports full repeal of the estate tax. Since many foundries are family-owned, they must plan for the estate tax if they want to keep the business operating after the death or retirement of the owner.  Permanent repeal will keep family-owned foundries operating for future generations.
  • Preserve LIFO (Last In, First Out) Accounting Method –  Continue to permit the use of LIFO, a widely accepted inventory accounting method which has been recognized in the U.S. tax code for more than 70 years. Repealing LIFO accounting would cause companies using LIFO to report their LIFO reserves as income, resulting in a massive tax increase on many foundries. 

International Trade 


AFS supports vigorous enforcement of U.S. trade laws. Too often, foreign countries have engaged in unfair and unlawful trade practices, such as currency manipulation, subsidies, and dumping, which result in an uneven playing field, and a shift of market share away from the U.S. These practices must come to an end.


U.S. metalcasters are major consumers of metals. Foundries are dependent on access to adequate supplies of globally priced raw materials to become and remain globally competitive. Countries such as China, in an effort to expand their manufacturing economies through exports and with heavy government subsidization, have dramatically increased their metals production capacities.  This excess capacity has led to increased shipments of metals and castings abroad.


For example, in 2000, China produced only about 11 percent of the world’s aluminum. Now, after joining the World Trade Organization (WTO) on December 11, 2001, it produces more than half. Meanwhile, the number of foundries in the U.S. has dropped from 2,380 in 2005 to about 1,950 today. This reduction is due in part to unfair foreign competition.


More than 20 percent of castings sold in the U.S. are made outside of North America, primarily from Asia. That statistic understates the impact of unfair trade practices, in that as the trade deficit has grown, more manufactured goods that contain castings are imported into the U.S. Needless to say, casting-sales statistics do not capture the value of castings that are part of finished goods imported into the U.S.


AFS supports:

  • Strong enforcement actions that will address unfair trade and market-distorting policies, and ensure a fair and even playing field for U.S.-based casting producers.
  • The inclusion of Buy-America requirements and manufactured in the U.S. provisions for  taxpayer-funded infrastructure projects.
  • New and updated trade agreements that strengthen North American metalcasters, and would crack-down against foreign firms re-routing various manufactured products, including castings, through third countries/regions, eliminate tariff and non-tariff barriers to U.S. exports, enhance reciprocal government procurement market access, and discipline currency manipulation and market-distorting state-owned enterprise (SOE) activities.
  • Federal investigations to review the strategic importance of metals and metalcasting to U.S. national defense and to the U.S. economy.
  • Reshoring. Educating all manufacturers and buyers on the advantages of reshoring. AFS is a sponsor of The Reshoring Initiative. 
  • Exports. AFS encourages member companies to explore exports as a means of broadening their customer base.

Infrastructure Policy


The nation’s infrastructure is one of our greatest assets.  It is the foundation of our jobs, quality of life, economic competitiveness, and even national security. Yet the nation’s transportation, water, energy, and communications infrastructure are crumbling, under-funded, poorly maintained, and inadequately designed to meet 21st century needs.  Most of our buried drinking water infrastructure was built 75-100 or more years ago. Substantial and long-term investments in all kinds of infrastructure are needed to expand our economy, grow jobs and compete globally. 

Metalcasters play a critical role in our nation’s infrastructure network – we help build infrastructure!  We manufacture key components for construction equipment, tractors and trucks, railroad, energy sector, water works, buildings, and so much more. In fact, over 40% of all castings are dedicated to infrastructure. America has a world-class economy and we should have world-class infrastructure to match. Investing in infrastructure is worth it.  Few investments would have a greater positive impact on our economy and the metalcasting industry than infrastructure. 

AFS is working to advance the following goals:

  • Support funding for Long-Term Projects.  Increased funding of infrastructure improvements should be directed towards long-term, multi-year projects that focus on rebuilding the nation’s bridges, roads, waterways, railroads and energy infrastructure. 
  • Streamline and accelerate the federal permitting process.  Our nation’s lengthy permitting and environmental review process can add to projects’ time and cost, while deterring the entry of private capital.
  • Ensure materials for infrastructure projects are produced in the U.S. Infrastructure projects should require that all iron and steel used to rebuild the nation’s infrastructure is produced in the United States, including metal castings. Specifically, the domestic preference provisions should be consistent with the longstanding application of the existing Buy America provisions for surface transportation projects administered by the Transportation Department.
  • Reinvest in our Nation’s Water Infrastructure.
    • Support full funding for the EPA State Revolving Loan Funds Programs. This federal-state partnership provides a permanent, independent source of low-cost financing for range of water quality infrastructure projects.
    • Support full funding for the Water Infrastructure Finance and Innovation Act (WIFIA). This new program provides long-term, low-cost credit assistance for financing large water or wastewater infrastructure projects. 
  • Complement and strengthen existing tools, such as municipal bonds, that successfully deliver infrastructure investments at the federal, state and local levels.

 

Safety & Health Policy


AFS members share the critical goal of ensuring the safety and health of their employees as a top priority in the workplace. Our member companies have made substantial efforts to decrease the number and frequency of workplace incidents and continue to work through AFS to share information and best practices to meet their shared goal of improving occupational safety and health. 

AFS’ Safety and Health Committee provides a wealth of information and services on metalcasting industry safety and health through our numerous safety resources, including quarterly meetings, webinars, seminars, and the annual association Environmental, Health & Safety Conference. AFS, along with OSHA, and other industry partners, participate in small business regulatory safety roundtables on occupational safety and health, issues hosted by the Small Business Administration’s (SBA) Office of Advocacy.

AFS has key concerns with:

  • OSHA's Final Respirable Crystalline Silica Standard -  The rule is technologically and economically infeasible. The final rule significantly lowers the permissible exposure limit (PEL), requires foundries to exhaust all feasible engineering and work practice controls to meet the new PEL and comply with a host of ancillary provisions. AFS, in conjunction with the National Association of Manufacturers (NAM), petitioned for review the agency’s silica rule.  That lawsuit was consolidated with other challenges to the rule in the U.S. Court of Appeals for the D.C. Circuit.  The case has been fully briefed and oral argument was held before a three-judge panel on September 26, 2017.  The case is now awaiting a decision of the court. Aside from the litigation, which AFS has pursued for over a year, AFS petitioned the Secretary of Labor to re-open the rule to evaluate the feasibility of meeting OSHA’s revised PEL and the appropriateness of certain ancillary provisions.  That petition is still before the Secretary.  AFS and NAM are engaged in discussions with OSHA to attempt to resolve the key issues and questions that the industry has with compliance.  These discussions are not intended to displace the litigation. The rule goes into effect on June 23, 2018.

  • OSHA’s 2016 final rule on Electronic Injury Reporting. This rule, which requires employers to electronically submit detailed injury and illness records to OSHA, could lead to inaccurate and incomplete conclusions about safety levels. Also, some forms of post-accident drug testing and accident-free incentive programs will be deemed to be unlawfully retaliatory.  OSHA should revise this rule and ensure that the beneficial employer programs for safety incentives and drug testing currently utilized by the metalcasting industry are not negatively impacted. 

AFS supports:

  • Ensuring that new and existing workplace safety regulations are as practical, performance-oriented, technologically attainable, and cost-effective as possible.
  • A cooperative enforcement approach at OSHA. The federal agencies and employers should work in partnership to advance workplace safety and health.
  • Codifying the Voluntary Protection Program (VPP), a key employer employee-OSHA collaborative workplace safety program. The Administration should also demonstrate its commitment to continuing the work of the VPP.