Comments

SMART/SMACNA Joint Letter to the White House Mar 15 2023

Upgrading Standards for Registered Apprenticeship Programs

On behalf of our thousands of union members and signatory contractors, the International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART) and Sheet Metal and Air Conditioning Contractors' National Association (SMACNA) would like to reiterate our appreciation for the opportunity to share our recommendations with the White House Task Force on Worker Organizing and Empowerment. The recommendations below address upgrading the standards for registered apprenticeship programs (RAPs) in 29 C.F.R. part 29 and supplement the recommendations in our December 6, 2022 letter to the Task Force, which focused primarily on requiring proof by an applicant for sponsorship of a RAP that the proposed program has “future sustainability,” i.e., it has the present and future financial and training capacity to provide broad-based, quality training to apprentices.

SMACNA Comments on Proposed Rule Mar 13 2023

“Guidance for Grants and Agreements,” 88 Fed. Reg. 8374

SMACNA Comments in support of the Office of Management and Budget’s (OMB) Proposed Rule, Guidance for Grants and Agreements, which implements the Build America, Buy America Act (BABA Act), as part of the Infrastructure Investment and Jobs Act of 2021 (IIJA).

SMACNA fully supports the IIJA – and, in particular, the “Buy America” portions of the BABA Act – because the law ensures that federal infrastructure investments are completed with American-made “iron, steel, manufactured products, and construction materials.  The “Buy America” requirements reinvest tax dollars in America, which creates jobs, ensures goods are produced under appropriate environmental and workplace safety standards, and protects America’s Economic and national security.

SMACNA Comments Dec 13 2022

Employee or Independent Contractor Classification Under the Fair Labor Standards Act

SMACNA comments in support of the DOL’s Notice of Proposed Rulemaking — Employee or Independent Contractor Classification under the Fair Labor Standards Act published Oct. 13, 2022. SMACNA believes that the construction industry needs stronger protections against the deliberate misclassification of workers as independent contractors — also called “worker status fraud.” SMACNA believes the DOL should develop rules specific to the construction industry to prevent unscrupulous contractors from deliberately misclassifying workers to gain an unfair advantage for law-abiding contractors that pay workers middle-class wages and benefits.

SMART/SMACNA Joint Letter to the White House Task Force Dec 06 2022

Upgrading Standards for Registered Apprenticeship Programs

On behalf of our thousands of union members and signatory contractors, the International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART) and Sheet Metal and Air Conditioning Contractors' National Association (SMACNA) would like to reiterate our appreciation for the opportunity to share our recommendations with the White House Task Force on Worker Organizing and Empowerment. These new recommendations address upgrading the standards for registered apprenticeship programs (RAPs) in 29 C.F.R. part 29 and supplement the recommendations concerning apprenticeship standards in SMART’s June 25, 2021 letter (attached) to the Task Force.

SMART/SMACNA Joint Comments Nov 04 2022

Requirements in the Inflation Reduction Act of 2022

The IRA’s massive investments to fight the climate crisis will incentivize expansion of workforce training and creation of career-sustaining, middle class jobs by providing expanded tax credits for taxpayers that satisfy prevailing wage and apprenticeship requirements.

SMART/SMACNA Joint Comments Nov 04 2022

On Requirements in the Inflation Reduction Act of 2022

We recommend that the Treasury Department require that home energy auditors hold the following certifications accredited by the ICB in order to receive credit: Total Building Energy Audit Technician, Indoor Air Quality (IAQ)/Ventilation Verification Technician, Indoor Air Quality/Ventilation Verification Contractor and Indoor Air Quality/Ventilation Verification Supervisor. These certifications hold third-party accreditation status, have strong standards, and play a critical role in auditing and assessing the energy performance of buildings. The ICB is a recognized leader in providing certifications for the heating, ventilation and air conditioning (HVAC) industry.

SMART/SMACNA Joint Comments Oct 18 2022

Requirements in the Inflation Reduction Act of 2022

SMART and SMACNA support efforts to make the WD-10 form more user-friendly in furtherance of the DOL’s goal of increasing the amount of usable data submitted in wage surveys. These comments focus primarily on the two most significant changes to the proposed WD-10: elimination of peak week as an indispensable means to increasing the total amount of data on which prevailing rates are based; and inclusion of a ‘‘picklist’’ of “labor classifications” from which a submitter may choose, along with a creation of a Directory of Classifications and Sub-classifications.”

SMART/SMACNA Joint Comments May 17 2022

The Proposed Rulemaking Updating the Davis-Bacon and Related Acts Regulation

SMACNA believes that by returning to the original 30-percent rule, more union contractors will be able to competitively bid for federal contracts since, under the terms of the 50-percent rule, there was the appearance that union wages did not accurately reflect the realities of the labor environment.

In addition, SMACNA member corporations and chapters support the Department of Labor's efforts because they include several enhancements that reflect technological changes in work processes in the nine decades since the Davis Bacon Act was enacted. These rules would improve the overall efficiency of the Act and its enforcement and ensure that wages do not become "stale" or outdated.