January 18, 2010

The Honorable Darrell Issa

The United States House of Representatives
CHAIRMAN: 2347 Rayburn House Office Building
Daniel D. Janka
President
MAG Industrial Automation Systems
Washington, DC 20515
Americas Group

1st VICE CHAIRMAN:

Eugene R. Haffely, Jr.
Dear Mr. Chairman:
Chief Operating Officer
Assembly & Test Worldwide, Inc.

2nd VICE CHAIRMAN & I am writing on behalf of AMT – The Association For Manufacturing Technology in
TREASURER:
Timothy B. Dining reply to your letter dated December 10, 2010. I appreciate the opportunity to comment
President & C.E.O.
Greenerd Press & Machine Company, Inc. on the impact of over burdensome regulations on U.S. manufacturers, particularly our
SECRETARY:
Kim W. Beck smaller companies. Excessive regulations hinder job growth and innovation – key
President & C.E.O.
Automatic Feed Co. drivers of a prosperous economy. Reining in regulatory costs along with bringing down
DIRECTORS: the structural costs that put U.S. companies at a competitive disadvantage is a guiding
Charles N. Clark, Sr.
Division President
Dukane Corp. – I.A.S. Division
principle of AMT’s Manufacturing Mandate, a copy of which I am pleased to include
Krestine Corbin
with this letter.
Chairman, President & C.E.O.
Sierra Machinery, Inc.

R. Stephen Flynn AMT represents U.S.-based manufacturing technology companies. Our members
President
Optical Gaging Products, Inc. provide the tools that enable production of all manufactured goods. In their workplaces
Michael Powell and in their products, safety and efficiency are critical elements of the manufacturing
President
Master WorkHolding, Inc. process. AMT members value the role our government plays in providing standards for
Carl Reed
President & C.E.O.
each. Unfortunately, in many cases, regulations are excessive, confusing and so costly
Abbott Workholding Products
that R&D and business development suffer as a result, hindering job growth and stifling
Richard A. Shore, Sr.
President innovation.
Automation & Modular Components, Inc.

Steven R. Stokey
Executive Vice President
Allied Machine & Engineering Corp.
This is particularly true with regulations originating from the Environmental Protection
Agency (EPA) and the Occupational Safety and Health Administration (OSHA), where
EX-OFFICIO:
Ronald F. Schildge it is obvious that regulators know little or nothing about manufacturing. Our companies
President
Eitel Presses, Inc. are not consulted for input, and the result is a convoluted set of regulations that make
Doug Currie
President & C.E.O.
compliance increasingly difficult and costly. In some cases, industry has more input on
Erie Press Systems European Union regulations than on the EPA’s. Segments of the manufacturing
STAFF: technology industry must now even deal with the Food and Drug Administration (FDA)
Douglas K. Woods
President which drew the responsibility for regulating lasers. Today, every laser machine has to
Peter R. Eelman
Vice President-Exhibitions &
be registered with the FDA. Talk about bakers regulating the trains – this is the actual
Communications
application of that old joke!
Patrick W. McGibbon
Vice President-Strategic Information
& Research
Linda G. Montfort The overwhelming majority of AMT members are small businesses and the regulatory
Vice President-Finance
& Human Resources burden is worst for them. According to a recent study by the Small Business
Christine T. Rasul
Vice President-Meetings
Administration’s Office of Advocacy, small manufacturers bear a disproportionate
& Conferences
share of the high cost of government regulations. Yet, these companies are looked to as
Jeffery H. Traver
Vice President-Business the innovators. They are the businesses that will discover safer, cleaner ways to make
Development
Paul R. Warndorf things.
Vice President-Technology

The government must take a more focused and deliberate approach in determining how
best to implement and distribute the regulatory burden so that manufacturers,
particularly small ones, are not competitively disadvantaged. Regulatory reform should
be one part of a comprehensive national strategy to help revitalize and

7901 WESTPARK DRIVE, McLEAN, VIRGINIA 22102-4206 PHONE 703-893-2900 FAX 703-893-1151
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The Honorable Darrell Issa
January 18, 2010
Page Two

strengthen our manufacturing sector – a strategy focused on driving innovation and increasing
competitiveness. AMT has been working to advance the principals of our Manufacturing Mandate
as the place to begin.

AMT’s Manufacturing Mandate calls for a coordinated federal manufacturing policy that: 1)
incentivizes innovation and R&D in new products and manufacturing technologies; 2) assures the
availability of capital; 3) increases global competitiveness; 4) minimizes structural cost burdens,
including costly regulatory compliance; 5) enhances collaboration between government, industry,
and academia; and 6) builds a better educated and trained “smart force.”

The Mandate advocates three major policy objectives to achieve these six goals:

1. Reduce uncertainty and foster innovation – The slow recovery is fueling continued uneasiness
over the future. A persistent fear that government will raise taxes and add to the regulatory burden
of small manufacturers stifles investment. Retroactive and short-term extensions of incentives help
in the very short-term, but not when developing a business plan even five years out. There is also a
skilled worker shortage of critical proportion in our industry, at a time when so many Americans are
unemployed. Congress and the Administration must come together to address these issues and turn
the focus on restoring confidence and encouraging innovation.

2. Enhance coordination and cooperation among agencies/departments – The Manufacturing

Mandate supports a consistent, cohesive approach to managing the government’s pro-manufacturing
initiatives. Duplicate efforts, complicated bureaucracies, and unclear directives waste valuable
federal dollars. The Mandate recommends establishing a central manufacturing policy structure
within the Executive Branch to develop policy, focus research, and coordinate implementation of
the manufacturing mandate strategies.

3. Utilize the existing infrastructure – In this time of strained budgets and high deficits, we must
leverage the resources already in place to help accomplish our goals. Existing manufacturing
technology communities of Manufacturing Extension Partnerships (MEPs)/economic development
centers, manufacturing companies, and academic institutions are excellent places to start., schools
and businesses working more closely together can maximize the effectiveness of MEPs,
public/private R&D, federal and state technology funding and other government programs and
services. Manufacturing technology communities – located across the country – are where
innovation and job creation are most likely to occur.

The 112th Congress has the responsibility of ensuring that a competitive manufacturing sector is at
the top of our national agenda. Efforts to root out impediments to our success, such as this one by
the Oversight and Government Reform Committee, are necessary. I hope we can count on your
support for all of the principles outlined in this Manufacturing Mandate. My staff and I welcome the
opportunity to meet with you and/or your staff for a discussion of what Congress can do to move
manufacturing to the top of our national agenda.

Best regards,

Douglas K. Woods
President

Enclosure