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PMA Comments in Opposition to House Bill 2238

June 07, 2024

May 31, 2024
Comments in Opposition of House Bill 2238

Submitted to:
Pennsylvania House of Representatives Environmental Resources & Energy Committee

Submitted by:
David N. Taylor, President & CEO Carl A. Marrara, Executive Director

The Pennsylvania Manufacturers’ Association (PMA) opposes House Bill 2238, sponsored by Representative Greg Scott, pertaining to bans on Per- and polyfluoroalkyl substances (PFAS) in products in the commonwealth.

Founded in 1909, PMA is the nonprofit, statewide trade organization representing the manufacturing sector in the state’s public policy process. Manufacturing directly employs 550,000 Pennsylvanians on the plant floor, sustaining millions of additional jobs in supporting industries, and generating more than $100 billion in gross state product. PMA’s mission is to improve Pennsylvania’s economic competitiveness by advancing pro-growth public policies that reduce the baseline costs of creating and keeping jobs in our commonwealth. Manufacturing is the engine that drives our economy here in Pennsylvania and across the United States, adding the most value and sustaining tens of millions of jobs on our shop floors and in supply chains, distribution networks, and vendor services. Because our sector adds the most value, manufacturing jobs have the highest salaries and best benefits in the marketplace.

We appreciate the opportunity to submit comments to the Pennsylvania House Environmental Resources and Energy Committee regarding House Bill 2238. Pennsylvania must not enact state laws or regulations that place the commonwealth at a competitive disadvantage with our competitor states. Pennsylvania laws and regulations should not be more stringent than federal regulations or laws unless there is a compelling reason that is unique to our commonwealth. Environmental regulations should be adopted based on sound scientific evidence to ensure that they are reasonable and achievable using existing technology. It is prudent that these regulations actually achieve real environmental benefits and do not advantage one sector of the economy to the detriment of another.

A Pennsylvania-specific across-the-board ban on all PFAS manufacturing and use of PFAS component parts in the manufacturing process would be detrimental to many vital industries in our commonwealth. This legislation would put Pennsylvania at a unique disadvantage and would drive entire industries out of state; severely disrupting supply chains and distribution networks for products that have no substitute and are needed to sustain modern society.

American manufacturing is at a crossroads. The same manufacturers that changed their lines to supply personal protective equipment, medical devices, and safety equipment are now finding their stride in response to challenges with excessive inflation and supply chain
disruptions. Additional, unrealistic regulations will inhibit our sector from fully bouncing back, leading to fewer U.S. jobs and more products being produced overseas. This unnecessary offshoring would be detrimental to our economy and our environment.