Comments

• Joint Comments of SMART and SMACNA - Registered Apprenticeship

  Mar 25, 2024 |1 min read — Regulatory Comments

  Joint Comments of the International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART) and the Sheet Metal and Air Conditioning Contractors' National Association (SMACNA) to the Proposed Amendments to the Standards for

• Joint Comments of SMART and SMACNA - Prevailing Wage, Registered Apprenticeship

  Oct 30, 2023 |1 min read — Regulatory Comments

  Joint Comments of the International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART) and the Sheet Metal and Air Conditioning Contractors' National Association (SMACNA) on the Prevailing Wage and Apprenticeship Requirements in

• Transferability and Direct Pay Proposed Rule

  Aug 14, 2023 |1 min read — Regulatory Comments

  SMACNA comments in support of the Internal Revenue Service’s (“IRS”) and the U.S. Treasury Department’s (“Treasury”) Proposed Rules, “Section 6418 Transfer of Certain Credits,” 88 Fed. Reg. 40496 (June 21, 2023) (hereafter “Transferability Proposed

• Transferability (Section 6418 Transfer of Certain Credits) Proposed Rule

  Aug 14, 2023 |1 min read — Regulatory Comments

  SMART and SMACNA address transferability from two perspectives: first, as supporters of compliance with prevailing wage requirements for the protection of workers and to protect signatory contractors who comply with labor standards from underbidding

• Upgrading Standards for Registered Apprenticeship Programs

  Mar 15, 2023 |1 min read — Regulatory Comments

  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

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

  Mar 13, 2023 |1 min read — Regulatory Comments

  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

• Employee or Independent Contractor Classification Under the Fair Labor Standards Act

  Dec 13, 2022 |1 min read — Regulatory Comments

  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

• Upgrading Standards for Registered Apprenticeship Programs

  Dec 6, 2022 |1 min read — Regulatory Comments

  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

• On Requirements in the Inflation Reduction Act of 2022

  Nov 4, 2022 |1 min read — Regulatory Comments

  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

• Requirements in the Inflation Reduction Act of 2022

  Nov 4, 2022 |1 min read — Regulatory Comments

  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

• In Support of the Use of Project Labor Agreements for Federal Construction Projects

  Nov 4, 2022 |1 min read — Regulatory Comments

  Comments on specific steps that the Treasury Department, individually or in coordination with the Wage and Hour Division (WHD) and/or Office of Apprenticeship (OA), may take to promote accountability, appropriate oversight, and enforcement and to

• Requirements in the Inflation Reduction Act of 2022

  Oct 18, 2022 |1 min read — Regulatory Comments

  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

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

  May 17, 2022 |1 min read — Regulatory Comments

  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

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