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Stephanie Salmon, AFS Washington Office; Jeff Hannapel & Christian Richter, The Policy Group, Washington, D.C.

Trump Administration Implements Steel and Aluminum Tariffs


On March 8, President Donald

Trump signed proclamations impos- ing a 25% tariff on imported steel and a 10% tariff on imported alumi- num pursuant to Section 232(b) of the Trade Expansion Act of 1962. Te tariffs went into effect March 23, and the proclamations do not set a date on which the duties will expire. Relevant imports, including those already in transit, that are entered at a U.S. port on or after March 23 will be subject to the additional duties. AFS has weighed in regularly with

Department of Commercials officials on the import challenges faced by both ferrous and nonferrous found- ries and the need to include iron, steel and aluminum castings in their


Interim Guidance Issued Concerning Employers that Failed to Electronically Submit 300A Injury and Illness Log

According to OSHA enforcement officials, nearly 200,000 employers have failed to comply with the Occu- pational Safety and Health Administra- tion’s (OSHA) new electronic record- keeping rule. The agency was expect- ing approximately 350,000 companies to submit their 2016 records and only received submissions from 153,653. Metalcasters with more than 20 employees were required to electroni- cally submit their OSHA Form 300A Summary of Work-Related Injuries and Illnesses for 2016 to the agency by the December 31, 2017 deadline. If a facility did not submit its 2016 300A log, it may be able to avoid a citation and/or penalty under the recently released, Interim Enforce- ment Procedures for Failure to Submit Electronic Illness and Injury Records, issued by OSHA’s director

14 | MODERN CASTING April 2018

of enforcement. The maximum penalty for failing to submit is $12,934. Employers can avoid a citation and/ or penalty during the interim guidance period if they fall into one or more of the following categories: • If the employer failed to submit, but immediately abates during the OSHA inspection by providing a paper copy of the records, an Other Than Serious citation will be issued with no penalty.

• If the employer failed to submit its 2016 data but shows it has already submitted its 2017 data, an Other Than Serious citation will be issued with no penalty.

• If the employer does not produce any records, an Other Than Serious citation will be issued with the ap- propriate penalty.

OSHA has until June 15 to inspect and issue these citations, as they can only cite for a rules violation if it has been commit- ted within six months of an inspection. Metalcasters must file their 2017 300A

reports electronically by July 1, 2018.

OSHA Delays Enforcement of Beryllium Standard Until May

On March 2, the Occupational Safety and Health (OSHA) announced it had pushed back the start of the enforcement date of the beryllium rule until May 11, 2018. The general industry standard had an effective date of March 10, 2017, but with employers having to comply with most elements of the rule starting March 12, 2018 (now delayed by two months). In January 2017, the agency issued new health standards addressing expo- sure to beryllium, which will impact some nonferrous foundries. The rule reduces the permissible exposure limit (PEL) of beryllium to 0.2 micrograms per cubic meter of air over the course of an eight- hour shift, as well as a new short-term exposure limit of 2 micrograms per cubic meter of air over a 15-minute period.

For additional information, contact Stephanie Salmon, AFS Washington Off ice,


investigation. AFS also submitted formal comments on both the steel and aluminum investigations. Te final tariff package does include aluminum castings. A number of AFS members have reported increases in their metal prices since the Administration’s tariff announcement. Te administration is negotiating

country exemptions and has initially exempted Mexico and Canada, as well as Australia. Te Commerce Depart- ment recently published procedures to govern requests for product exclusions. U.S. companies can seek exemptions if the material they want to import can’t be sourced at a reasonable cost domes- tically, or if there is a national security interest for the exemption.

The Trump administration’s

proclamations have been met with threats of retaliation from major trading partners. The European Commission has prepared a pre- liminary list of items the United States exports that may be subject to trade remedies. Many of these products were targeted to exert political pressure on congressional leadership, including goods with strong ties to the home states of some congressional leaders. History suggests the tariffs could be short- lived. In 2002, the Bush adminis- tration put a 30% tariff on import- ed steel but scrapped the penalty 20 months later after Europe and others threatened retaliation.

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