Like many in our industry, I have been paying close attention to the AIS Provision and what it means to our customers, suppliers, and distributors. I recently attended a webinar that clarified the current implications of the American Iron and Steel (AIS) Provision with regard to the expiration of the National Product Waiver.
The AIS Provision requires Clean Water State Revolving Fund (CWSRF) and Drinking Water State Revolving Fund (DWSRF) assistance recipients to use iron and steel products that are manufactured in the US. Until recently, there was a National Product Waiver in effect, which temporarily excused recipients from compliance, and permitted the use of imported Stainless Steel Nuts and Bolts. However, in 2018, the EPA conducted a study in which they concluded that there was sufficient capacity to fill AIS demand, and in response to this, the waiver was allowed to expire on February 24, 2020.
There are still some specific waivers that can be requested, and some interesting aspects to the current situation. Key takeaways from the webinar are as follows:
- All products purchased on or before February 24, 2020 are covered by the waiver.
- All products purchased after February 24, 2020 must comply with AIS.
- The Minor Components Waiver probably won’t cover the stainless steel nuts and bolts, as they are typically greater than 5% of the materials cost of the product.
- The De Minimis Waiver likely won’t cover these components as they are generally not incidental.
- If an AIS-compliant product cannot be sourced in a particular instance, the loan recipient can apply for a Project-Specific Waiver. Further information on the waiver request process is available here: https://www.epa.gov/cwsrf/american-iron-and-steel-requirement-waiver-request-process
I am pleased to confirm that SIGMA is in a position to supply AIS compliant stainless nuts and bolts for both mechanical joint and flange joint applications, and can also supply imported product if a waiver is procured.
For additional information, please contact your local SIGMA branch: http://www.sigmaco.com/contact/.