IMA-NA Accomplishments

The members and staff of the Industrial Minerals Association - North America (IMA-NA) represent a wide range of knowledge and ability, and the organization engages in a variety of issues for the betterment of the industry. The following is a partial list of our recent accomplishments.

In 2007 and 2008, IMA-NA lobbyists played a key role on Capitol Hill attempting to re-structure the Supplemental Mine Improvement and Emergency Response (S-MINER) Act to meet the needs of the industrial minerals industry. These efforts succeeded in raising awareness of the excesses of the legislation that narrowly passed the House. Not only did we succeed in obtaining a Statement of Administrative Position against the bill, but secured sufficient bipartisan support to sustain a presidential veto.

In 2007 and 2008, IMA-NA played an active role in attempting to re-structure Mining Law reform legislation in the House. Of particular concern are the need to recognize that industrial minerals merit different royalty treatment than precious metals and the need for industrial minerals to continue to remain locatable under any meaningful Mining Law reform. IMA-NA secured sponsors for amendments to achieve these outcomes, but the amendments were defeated. IMA-NA is actively pursuing such provisions in any Senate legislation.

IMA-NA succeeded in helping secure passage of legislation in the Senate that would ban the use of asbestos, except in rare circumstances. The bipartisan measure passed by unanimous consent. IMA-NA opposes an alternative approach contained in a House bill that would establish a zero tolerance for naturally occurring asbestos not intentionally added to mineral, or other, products.

Climate change legislation recently was passed by the House of Representatives. IMA-NA succeeded in getting the soda ash industry recognized as an energy-intensive sector meriting carbon credit offsets. IMA-NA is actively working in the Senate to expand the eligible industries to include industrial minerals operations. It also is working to ensure that process emissions, as opposed to combustion emissions, are not included in a facility’s carbon profile.

IMA-NA opposes efforts to expand jurisdiction under the Clean Water Act to all waters of the United States. Currently, the statute is applicable only to navigable waters of the United States. This congressional initiative comes in response to recent decisions by the Supreme Court upholding limitations on federal jurisdiction contained in existing law.

IMA-NA continues to support efforts to maintain funding and increase the prominence of the Minerals Information Team (MIT) currently housed within the United States Geological Survey (USGS).

IMA-NA also continues to support efforts to maintain funding for mine safety and health research by the National Institute for Occupational Safety and health (NIOSH).

The Bush Administration had sought to impose a tax on explosives users (the largest non-military user is the mining industry) to offset costs associated with new Bureau of Alcohol, Tobacco, Firearms and Explosives regulations focused on combating terrorism. Congress each year refused to impose the user fee and, following years of consistent industry opposition, the Administration dropped the user fee proposal in its FY 2008 budget proposal.

IMA-NA provides regular input to Congressional authorizing, appropriations and budget committees regarding the federal budget and its impact on the industrial minerals industry.

IMA-NA challenged the Mine Safety and Health Administration’s (MSHA) final rule on asbestos. While IMA-NA supports the lowering of the permissible exposure limit for asbestos, it objected to the broad language contained in the text of the final rule compared with the specificity contained in the preamble to the rule. IMA-NA is seeking clarification of the final rule in settlement discussions with the agency. IMA-NA fully supports the technical amendment that emerged from settlement discussions.

IMA-NA submitted comments on the Department of Homeland Security’s interim final rule entitled “Chemical Facility Anti-Terrorism Standards,” specifically “Appendix A” which lists the “DHS Chemicals of Interest.”

IMA-NA submitted comments to the U.S. Department of Labor’s Employment Standards Administration to inform its consideration and review of the Department’s administration of the Family and Medical Leave Act of 1993.

IMA-NA submitted comments to the National Institute for Occupational Safety and Health (NIOSH) on its draft document: Asbestos and Other Mineral Fibers: A Roadmap for Scientific Research.

IMA-NA submitted comments to the National Toxicology Program upon the nomination of “Asbestos, naturally occurring and atypical forms [1332-21-4]” for toxicological studies.

IMA-NA provided comments to the Administrator of the Environmental Protection Agency (EPA) on a national study to address scientific questions concerning the measurement, health effects, and potential risks associated with asbestos and similar materials.

IMA-NA submitted data and comments to the EPA on its proposal to revise air pollution emission standards (New Source Performance Standards) for industrial minerals.

IMA-NA provided comments to the National Academy of Sciences ad hoc Committee on Critical Mineral Impacts on the U.S. Economy regarding the importance of maintaining a national capacity to assess critical mineral resources both within and outside the U.S.

The U.S. Mine Safety and Health Administration (MSHA) and IMA-NA have formed an Alliance to improve miner safety and health through cooperative efforts in education and training, technical assistance, mining industry outreach and communications. The Alliance has developed safety and health education and training programs tailored to industrial minerals operations, best practices, and exemplary applied engineering controls. Awards are presented each year to IMA-NA member companies with outstanding safety records

Through our Alliance with the Mine Safety and Health Administration, IMA-NA produced a Practical Guide to an Occupational Health Program for Respirable Crystalline Silica.

IMA-NA has teamed up with the National Institute for Occupational Safety & Health (NIOSH) and created an Ergonomics Task Force to address this issue. The mission of the Ergonomics Task Force is to provide information leading to the reduction of musculoskeletal injury and illness rates within the industrial minerals industry. Ergonomic injuries accounted for 87% of all injuries in the industrial minerals industry in 2008.

IMA-NA obtained funding from the U.S. Fish & Wildlife Service (FWS) to assist member companies with reclamation efforts that go beyond compliance. Through the FWS’s Partners for Fish and Wildlife Program, which provides financial and technical assistance to private landowners to improve wildlife habitat, IMA-NA has worked with member companies to meet the requirements for this funding opportunity.

Through our Dust Control Task Force, IMA-NA is collaborating with the National Institute for Occupational Safety and Health to produce a Dust Control Handbook for industrial minerals processing that will be available in late 2009/early 2010.