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Colorado Small Businesses and Manufacturers Discuss the Growing Burden of Federal Regulations with Congressman Tipton

Tuesday, 21 October 2014

For Immediate Release                                                                                 October 21, 2014                                                                                                                                                                  

Colorado Small Businesses and Manufacturers Discuss the Growing Burden of Federal Regulations with Congressman Tipton 

New Study Finds Federal Regulations Cost the Economy $2 Trillion Annually

GRAND JUNCTION, COLORADO –The National Federation of Independent Business (NFIB) and Club 20 met with dozens small businesses and manufacturers to discuss the growing burden of federal regulations with Congressman Scott Tipton (R-3) at Leitner-Poma, a local aerial lift manufacturing company. The event explored the findings of a new national study on regulations, conducted by Lafayette College economists Nicole V. and W. Mark Crain for the National Association of Manufacturers, that found federal regulation costs the American economy $2.028 trillion in lost economic opportunity each year.

“In order to keep America competitive, we must work towards a less cumbersome federal rule-making process. Federal regulations, we can all attest, are essential to help safeguard our communities and our businesses. However, the current federal process is broken,” said Congressman Scott Tipton. “We cannot have a regulatory system that costs over $2 trillion and not expect this to impact economic growth across the country.”

According to the study, small businesses and manufacturers are disproportionately impacted by federal regulations. The average cost per employee that a small business must pay to comply with federal regulations is now $11,724 a year, while small manufacturers pay an astounding $34,671 per employee per year.

Tony Gagliardi, NFIB-CO state director, added, “Business owners from across Colorado approach me with the same story:  outdated and duplicative regulations are handcuffing their ability to grow.  With over 3,300 regulations in the pipeline, is it any wonder that small business owners feel their voices aren’t being heard in Washington?   We applaud Congressman Tipton for understanding the regulatory burdens facing small businesses in our state and actively working to change the process.”

“The new study gives credence and a measurable proof to the growing regulatory burden manufacturers face,” said XX, president of Club 20. “These job-creators look to Washington to implement smarter regulatory policies, ensuring that our community is preserved, and avoiding roadblocks to economic growth. We need to find a better balance.”

According to Rick Spears, CEO of Leitner-Poma, “As a manufacturer in Colorado, our company takes pride in creating safe products in a safe environment. Sadly, federal rules have become an obstacle to our success. Regulations are not the problem, rather it is the arbitrary and confusing rule-making process. Regulations impact small manufacturers on a much larger scale than any reasonable person could understand, and as a result, we are left with fewer resources to grow and expand our companies.”


Congressman Guthrie Discusses the Cost of Federal Regulations with Kentucky Small Businesses and Manufacturers

Thursday, 25 September 2014

FOR IMMEDIATE RELEASE:                                                            September 25, 2014

 Congressman Guthrie Discusses the Cost of Federal Regulations with Kentucky Small Businesses and Manufacturers

New Study Finds Federal Regulations Cost the Economy $2 Trillion Annually

Bowling Green, KY — U.S. Congressman Brett Guthrie (R-KY-5) joined the Kentucky Association of Manufacturers (KAM) and National Federation of Independent Businesses (NFIB) today to discuss the findings of a new national study on the cost of federal regulations. The research, conducted by Lafayette College economists Nicole V. and W. Mark Crain, found that federal regulations costs the American economy $2.028 trillion in lost economic opportunity each year with small businesses and manufacturers impacted the most.

“The $2 trillion federal regulatory burden touches every one of us,” Congressman Guthrie said. “These regulations are affecting small businesses and small manufacturers across Kentucky, and making it difficult for these businesses to make the investments necessary to grow the economy and create new jobs.”

Greg Higdon, president of KAM, added, “The Crains’ research shows a federal regulatory system crying out for improvement. The rule-making process is littered with ineffective regulations and outdated policies that hold back economic growth. And, our economy cannot afford to keep carrying this burden.”

According to the Crains’ research, the average price per employee that a small business must pay to comply with federal regulations is now $11,724 a year, while small manufacturers pay an astounding $34,671 per employee per year.  These estimates are consistent with prior studies, showing the cost of regulatory compliance disproportionately affects small firms.

“The more rules imposed by the government and bureaucratic red tape placed in the way, the harder it is for small businesses to invest in and create new jobs. And not a day goes by without the worry of what new rule or regulation the federal government might impose next,” said Tom Underwood, Kentucky state director for the NFIB. “Being an entrepreneur is difficult enough without the federal regulatory machine working overtime to make it nearly impossible to own a successful small business.”

 


Holly Springs and NFIB: Federal Regulations Are Crushing North Carolina Job Growth and Investment Onerous regulations cost trillions in lost economic opportunity nationwide

Thursday, 11 September 2014

Holly Springs and NFIB: Federal Regulations Are Crushing North Carolina Job Growth and Investment Onerous regulations cost trillions in lost economic opportunity nationwide

Holly Springs, NC – Dozones local business owners and community leaders joined Holly Springs Mayor Dick Sears and the National Federation of Independent Businesses (NFIB) this morning for a conversation about the growing regulatory burden and its impact on new investment and job creation in North Carolina.

“When the local shop owner spends more time filling out paperwork than they do selling to customers here in Holly Springs, something’s wrong,” said Mayor Sears. “There is a direct and undeniable correlation between the ineffective federal regulatory system and the challenge small businesses here face in investing in the future and hiring new employees.”

“The growing regulatory burden is often the number one concern voiced by our members, not just in North Carolina, but throughout the country,” said NFIB-NC state director Gregg Thompson. “It’s clear that small businesses in Holly Springs, and elsewhere, are looking to Washington to create a more effective rule-making system. Everyone understands the importance of regulations, but small business owners don’t understand the conflicting, outdated, and ineffective rules that make the regulatory system so cumbersome and impossible to navigate.”

The regulatory problem has become more pronounced in recent years as the number of new regulations considered by the federal government has grown. As of May, there were 3,348 proposed rules waiting to be implemented with nearly one-third of the pending rules slated to impact small businesses directly. And according to a new study by Lafayette College economists Nicole V. and W. Mark Crain, small businesses pay an estimated $11,724 per employee per year to comply with federal regulations.

The burdensome nature of the federal regulatory process has made starting a business in the United States more difficult than ever before. Where once it was a place that entrepreneurs felt comfortable taking risk on new ventures, the United States now trails countries like Romania, Panama, and Hungary as places friendly to business startups, according to the World Bank Group report, “Doing Business 2014.”  In fact, since the 1980s, the annual rate of new business starts in the U.S. has shrunk by 28 percent, according to a recent analysis of U.S. Census Bureau data in the Wall Street Journal.

“We see the impact of federal regulations on small businesses here in Holly Springs, and feel it across the Tar Heel State,” Mayor Sears added. “Unfortunately, the federal government has not reached this same understanding. This is why discussions, like the one we’re having today, are imperative to raise awareness of the problem and bring the changes necessary to improve the rule-making process.”

Through its Small Businesses for Sensible Regulations coalition, the NFIB has been working to raise awareness and build support for common-sense reforms to the regulatory process, including increased public participation in crafting rules and more rigorous analysis of the costs and benefits of major regulations.


NFIB: New Study on Regulations Should Trigger Alarms Washington

Wednesday, 10 September 2014

NFIB: New Study on Regulations Should Trigger Alarms Washington
 Study by manufacturers shows how regulations siphon capital from economy and hurt small businesses 

Washington, DC (September 10, 2014) — The National Federation of Independent Business (NFIB) today said that a new study released by a group representing American manufacturers should force Congress to get serious about taming a regulatory system that is increasingly, and perhaps prohibitively, expensive for small businesses.

“The real cost on small manufacturers, and therefore the larger cost to the economy, is staggering according to this research,” said Dan Bosch, NFIB Manager of Regulatory Policy.  “The relationship between federal regulations and economic policy is badly out of balance and it’s undermining everything that the Administration and Congress say they want to accomplish.”

The report, by the National Association of Manufacturers, finds that the average American company with 50 or fewer employees pays nearly $12,000 to comply with regulations.  Remarkably, the average small manufacturer (those with 50 or fewer workers), must pay nearly $35,000 per year, per employee to be in compliance.

“A small manufacturing firm with 10 employees must spend $350,000 per year, before they make a single dollar in profit, to comply with federal regulations,” said Bosch.  “That’s a massive barrier to entry for small businesses and a powerful incentive to invest and create jobs outside of the United States.”

President Obama and every member of Congress claim as a central economic policy the revitalization of the manufacturing sector, which has shed millions of jobs over the past decade under withering pressure from overseas competitors whose regulatory costs aren’t nearly as high.  That’s the right goal, said Bosch, because manufacturing jobs generally pay more than service sector positions.  Clearly, though, that goal is undermined by the bewildering proliferation of regulations and the costs they impose on small businesses.

“It’s always been one of the main pathways to the middle class for Americans and the federal regulatory bureaucracy is now blocking it,” he said.  “We’re not going to have a serious jobs policy, or a serious economic policy, unless we get serious about reigning in the regulatory system.”

NFIB is part of a coalition of organizations calling for sensible regulations.  Its website provides research on the rules affecting small businesses and their effect on the economy.  For more information about NFIB please visit www.nfib.com.


U.S. Senator Chris Coons (D-Del.) Addresses Delaware Small Businesses and Manufacturers on Removing Regulatory Barriers to Competitiveness

Wednesday, 20 August 2014

U.S. Senator Chris Coons (D-Del.) Addresses Delaware Small Businesses and Manufacturers on Removing Regulatory Barriers to Competitiveness

WILMINGTON, DELAWARE – The Delaware State Chamber of Commerce and Delaware Manufacturing Association today hosted U.S. Senator Chris Coons (D-Del.) and nearly 80 state manufacturers to discuss barriers to growing Delaware’s manufacturing base, especially the impact of federal regulations. The event, entitled “The Future of Manufacturing in Delaware: How the Current Regulatory Environment Impacts its Sustainability and Growth,” explored the relationship between federal mandates crafted in the nation’s capital and the First State’s economic activity. Senator Coons expressed his ongoing commitment to remove barriers for manufacturers while ensuring needed protections for workers, the environment and the public.

“It’s critical that we work together to ensure American manufacturers and small businesses can grow and compete,” said Senator Chris Coons. “From investing in American workers and supporting the research that drives innovation, to ensuring regulations protect the public and don’t overburden small businesses, there is so much we can do to build a foundation for job creation today and tomorrow. Manufacturing has been one of the bright spots of our nation’s economic recovery, and I’ll continue to work hard to ensure its revival is strong and sustained.”

Following remarks by Senator Coons, WDEL talk radio personality Rick Jensen moderated a panel discussion with A. Richard Heffron, president of the Delaware State Chamber of Commerce; Paul Morris, interim executive director of Delaware Manufacturing Extension Partnership (DEMEP); Robert Prybutok, president of Polymer Technologies; and, Mark Puzzo, operations manager of Atlantis Industries. While the panelists pointed out that many regulations play a critical role in outlining the rules of the road and ensuring protections, they noted several examples of the dysfunctional nature of the current federal regulatory process that has cost Delaware businesses significant time and resources.

Rich Heffron, president of the Delaware State Chamber, said, “We are grateful to Senator Coons for leading a critically important discussion about modernizing the ways federal regulations are handed down.  With a strong manufacturing background, Sen. Coons recognizes that Delaware businesses are not looking for a free pass, but they require a stable environment to invest, expand, and comply with various regulations.  We appreciate his leadership in Washington and will continue to urge greater attention to this important issue.”

“Here in Delaware, we take pride in our strong manufacturing base, but a complex, costly and inconsistent regulatory process in Washington threatens to undermine our industry’s competitiveness,” said Robert Prybutok. “Small manufacturers face a disproportionate compliance burden than larger businesses and when we are spending the majority of our time on paperwork and tracking new mandates, there are fewer resources to grow and expand the business, make it more efficient, and plan for the future.”

Mark Puzzo noted, “Regulations play an important role in our business operations no doubt.  But all too often, we aren’t made aware of a new requirement or get word of a new rule focused on fixing problems that don’t exist. In order to keep our businesses competitive, we need smarter government and must address the serious problems that exist and create a more collaborative and effective method for determining the real risks.”


Small Businesses for Sensible Regulations Coalition Applauds House Committee’s Hearing on Regulatory Oversight

Wednesday, 25 June 2014

WASHINGTON – Dan Bosch, manager of regulatory policy for the NFIB, made the following statement today regarding the House Oversight and Government Reform Committee hearing, “Management Failures: Oversight of the EPA.

“While President Obama pledged early in his Administration to promote an “open exchange of ideas” and greater public participation in the regulatory process, his administration – especially the EPA – has regularly failed to take into account small business input or direct or indirect impacts to their business. Too often newly proposed rules including recent changes to Clean Water Act permitting do not include required analysis of undue compliance burdens to small businesses.”

“As a top issue facing America’s small businesses, improving the regulatory process to be more transparent, accountable and less burdensome should be a top priority of EPA Administrator McCarthy and the entire administration.  The Administration’s Unified Agenda of regulations released over Memorial Day weekend shows nearly 3,300 regulations in the federal pipeline.  While small businesses are steadfastly committed to regulatory compliance and ensuring environmental, worker and public protections, in recent years, the regulatory burden has grown and threatened our members’ ability to create jobs and expand their businesses.  The current regulatory process at agencies like EPA is not working and requires reform.”

 

For more information on the campaign, visit www.sensibleregulations.org


NFIB Fights EPA’s Expanded Definition of Navigable Waters

Wednesday, 11 June 2014

The National Federation of Independent Business’ Small Businesses for Sensible Regulations coalition applauded the House Transportation and Infrastructure committee today for shining a light on the controversial Administration proposal to expand the definition of navigable waters – in some cases to include even small depressions or farm ponds – that receive federal protection under the Clean Water Act.

Dan Bosch, manager of regulatory policy for the NFIB, said the proposed rule, with its vague definition and potential for onerous fines and stiff penalties on small businesses, would unfairly impact small business owners:

“Only in the bureaucracy of the Environmental Protection Agency would it make sense to reclassify land as a ‘federal water’ if it accumulates water at any point in a year.  But that is what EPA is proposing with its vague new definition of what constitutes waters of the United States.  This proposal stands to deter small business owners from land development and investment with the specter of thousands of dollars in permitting fees or fines,” Bosch said on behalf of the coalition.

NFIB’s review of the proposed rulemaking on “Definition of Waters of the U.S.” finds that it will have a tremendous impact on small businesses across virtually every sector. EPA has alleged that since this is a simple definition change, there are no major costs directly imposed on small businesses. However, there will certainly be costs directly imposed on small businesses through the permit process and other compliance requirements. In addition, the proposed rule makes it clear that many waters will need to be determined on a case-by-case basis, therefore providing little, if any, additional certainty.  NFIB successfully petitioned for a longer comment period earlier this year and EPA is now accepting comments through October 20, 2014.

Added Bosch, “Sadly, this proposed rule is just another unfortunate example of the backwards nature of the modern regulatory process; one devoid of transparency and any consideration of the impact of new regulations on small business owners and manufacturers across the country. Simple, common-sense improvements can be made today to change the rule-making process so it benefits everyone – from consumers and the environment to the small business owner looking to build a new shed on his land right near a pond full of yesterdays’ rain water.”

BACKGROUND ON THE PROPOSED RULE

Under the Clean Water Act, the EPA and Army Corps of Engineers (ACE) have authority over “waters of the United States,” even those on private property. If land is defined as a wetland, or has another significant connection to downstream water quality, the owner must get a permit from EPA/ACE in order to do any kind of development or alteration to that parcel. As of a decade ago, the average cost of a Clean Water Act permit was more than $270,000. Altering land without a permit can lead to fines of up to $37,500 per day.

Under the proposed rule, the EPA is seeking to vastly broaden the definition of what a wetland is. In the proposed rule, the agencies are aiming to go so far as to regulate and with a ditch or hole that collects water for as little as a few days per year. Additionally, under federal law, if a rule will have a significant impact on small businesses EPA must analyze it and meet with a group of small business owners to get feedback before it is published. However, EPA never conducted such a meeting because it wrongly claims the rule will have no harmful impact on small businesses.

For more information on the campaign, visit www.sensibleregulations.org. And read NFIB’s letter requesting that the agencies extend the written comment period.


Delaware Business Leaders Featured In “Small Businesses for Sensible Regulations” Campaign

Wednesday, 5 March 2014

For Immediate Release                                        Contact:

Delaware Business Leaders Featured In “Small Businesses for Sensible Regulations” Campaign

 

DOVER, DE – March 5, 2014 –Delaware business owners Tim Boulden and David Lyons have been chosen by the National Federation of Independent Business (NFIB) to be featured in the Small Businesses for Sensible Regulations national video series.

Both men were also among 30 state business leaders who met Friday morning with U.S. Sen. Tom Carper to thank him for his stalwart leadership in Washington on the issue of regulatory reform and to urge him to advance balanced, sensible regulatory solutions in the months ahead that help small businesses.

Boulden is president of Boulden Brothers Propane, Boulden’s One Hour Heating & Air Conditioning, and Boulden Brothers Plumbing headquartered in Newark. Lyons is president and CEO of the Lyons Companies, based in Wilmington.

Jessica Cooper, the NFIB state director for Delaware, said, “We are thrilled to have these exemplary Delaware small business owners showcased in our effort to have a national conversation about the broken federal regulatory process. With more than 90 years of combined experience creating jobs and running successful businesses in Delaware, Mr. Boulden and Mr. Lyons talk directly to the challenges posed by a regulatory process that places a greater emphasis on enforcement over compliance. We strongly believe that their stories will help more people realize that the regulatory process, as currently situated, benefits no one – neither the businesses trying to create jobs nor the public’s safety.”

Boulden said of his participation in the video, “It’s always been troubling to me that we only hear Washington lawmakers and the Administration talk about the concerns of small businesses during an election year.  To my 50 employees and their families who feel the burden the regulatory process places on my businesses, this is an issue that deserves year-round attention. Discussing the various common sense, bipartisan ways of improving the regulatory process is something that should always be on the agenda regardless of when the next election is taking place.”

Added Lyons, “Regulations are critical, but we can have a system in place that does things smarter and benefits everyone. I’ve seen how the current regulatory process has negatively affected entrepreneurs and also forced new start-ups to go about doing business in a different manner. There’s no reason we shouldn’t improve a regulatory process that both political parties agree needs to be modernized.”

Click here to watch Tim Boulden’s interview or here for David Lyons.

About Small Businesses for Sensible Regulations: Small Businesses for Sensible Regulations is a national effort focused on protecting small businesses and American jobs from the impacts of regulations recently proposed by the Obama administration. Learn more at http://www.sensibleregulations.org.

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Delaware Businesses Leaders Discuss Partisanship in Washington and Federal Regulation with U.S. Sen. Tom Carper

Friday, 28 February 2014

 

Carper


 

FOR RELEASE: February 28, 2014
CONTACT:
Emily Spain (Carper) (202) 224-2441 or [email protected]
Cheryl Corn (DSCC) (302) 576-6572 or [email protected]
Jack Mozloom (NFIB) (609) 989-8777      

Delaware Businesses Leaders Discuss Partisanship in Washington and Federal Regulation with U.S. Sen. Tom Carper 

WILMINGTON, Del. – More than 30 small business owners, manufacturers and community leaders met this morning with U.S. Senator Tom Carper (D-Del.) to discuss partisanship in Washington and federal regulation.

In a tour and business roundtable at Masley Enterprises in Wilmington, local business leaders shared their stories and offered input on the Affordable Care Act and how regulations could be issued, reviewed, and enforced to ensure worker and environmental protections while also enabling local businesses to grow and create jobs.  Sen. Carper and the participants also discussed the challenge of getting things done in an increasingly partisan Washington.

Senator Carper, the senior senator from Delaware, who chairs the Senate Homeland Security and Governmental Affairs committee, which oversees personnel and management issues across the federal government said, “One of the best parts of my job as a Senator is getting to meet regularly with my constituents to hear about the issues that are important to them and how I can be helpful.  Today’s conversation with local business leaders about the challenges and opportunities they face, and how my colleagues and I in Washington can help create a nurturing environment for job creation, was valuable and informative.  I have always believed that we don’t have to choose between having strong economic growth and strong regulations to protect our workers, our environment and our public health; we just need to strike the right balance between these important priorities by using some common sense. The Obama Administration has taken some meaningful steps to improve federal rule making to ensure that they are as efficient and effective as possible, but I always appreciate getting feedback from my constituents on what is working and where we can continue to improve our efforts. I think today’s conversation was helpful in that regard.

Richard Heffron, the interim president of the Delaware State Chamber, said “Our members aren’t looking to get rid of regulations; we just need a smarter regulatory process. We need a system that does a better job of anticipating the impact that a new rule will have on businesses and manufacturers before it is implemented. A streamlined process, with greater transparency, will give our job creators the freedom to reinvest and expand their operations. I appreciate Senator Carper’s willingness to meet with our members today.”

Added Tim Boulden, of Newark-based Boulden Brothers Plumbing, Propane, and Heating & Air Conditioning,  “The U.S. Small Business Administration’s study, ‘The Impact of Regulatory Costs on Small Firms,’ said the total annual cost of following the rules for a small business is $10,585 per employee, or about $2,830 more than a large business. That can be a huge burden.  The number of new and existing regulations we face every day  put a significant strain not only on me, but also the people I work with. I’d like to thank Senator Carper for meeting with us and listening to our concerns and our suggestions.” 

Jessica Cooper, the Delaware state director for the National Federation of Independent Business (NFIB), talked about her organization’s focus on making sensible changes to the regulatory process.  “Regulations play a critical role in safeguarding our member businesses, their customers and the community at large,” Cooper said. “But increasingly, the regulatory process has been more of an impediment to businesses with more than 3,000 federal rules in the pipeline today. New rules are drafted without consideration or review of the compounded impacts with other regulations. We need to ensure that the government works with businesses of all kinds to better address their needs.”

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U.S. Sen. Carper (D-Del.) meets with members of the Delaware State Chamber of Commerce and the National Federation of Independent Business (NFIB).


NAM and NFIB Call For Action to Modernize Regulatory Process

Wednesday, 26 February 2014

NAM and NFIB Call For Action to Modernize Regulatory Process
NAVIGATING COMPLEX FEDERAL REGULATORY SYSTEM REMAINS BARRIER TO SMALL BUSINESS AND MANUFACTURING GROWTH            

WASHINGTON (February 26, 2014) – The National Association of Manufacturers (NAM) and the National Federation of Independent Business (NFIB) are joining forces to urge for long-overdue reforms to the overly complex and inefficient federal regulatory process. The partnership was announced during a panel event on federal regulations this morning. During the course of the upcoming year, the two organizations will utilize the full weight of their grassroots networks in an effort to engage with Congress and the Administration on the need for regulatory improvements.

Jay Timmons, president and CEO of the NAM, said, “This is a strong and necessary partnership because manufacturers and small businesses face a disproportionate burden of all regulatory costs. While manufacturers recognize the need for regulation, the scope and complexity of rules have made it harder to do business and compete in recent years. This is a trend that simply cannot continue and is easily solved with several common-sense fixes. We can achieve a streamlined regulatory process with increased accountability and transparency that will protect businesses, manufacturers and the consumers.”

NFIB President and CEO Dan Danner added, “Poll after poll indicates most Americans feel Washington is doing too much, too fast on regulations. Time and time again, we hear from our members about the complex regulatory climate and how, with a little more transparency and openness, the regulations would be more effective and work more efficiently for everyone. This is a bipartisan issue that Congress can rally behind and move quickly to address.”

This morning’s event, which included opening remarks by House Majority Whip Rep. Kevin McCarthy (R-CA), fell during the House of Representative’s week-long focus on regulations. Panelists included former Virginia Gov. George Allen; former U.S. Senator Blanche Lincoln (D-AR); Susan Dudley, the Director of the George Washington University Regulatory Studies Center and the former administrator of the Office of Information and Regulatory Affairs (OIRA); Robert Weissman, president of Public Citizen; and Philip Howard, author of The Death of Common Sense.

Navigating federal regulations continues to be one of the top problems facing small business owners and manufacturers. The regulatory process leaves businesses mired in uncertainty and spending precious time and money trying to navigate applicable regulatory requirements. This results in fewer resources being invested in hiring new employees or growing their business. In 2013 alone, business owners and manufacturers spent more than 67 million hours filling out paperwork at a cost to the economy of approximately $112 billion. And according to a study by the Manufacturers Alliance for Productivity and Innovation (MAPI), compliance costs for manufacturers have increased an average of 7.6 percent per year since 1998, while manufacturing output has grown at an anemic 0.4 percent.

The NAM and NFIB intend to talk about how small businesses and manufacturers need regulations that are thoughtfully crafted, analyzed, implemented, and enforced to protect the public, workers and the environment as intended. Too often today, rules are drafted without input from the sectors responsible for implementing them and without a review of the compounded impacts with other regulations. More federal regulations are not always needed, and priority should be placed on reviewing and enforcing those already on the book.


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