As we have been discussing in the Quick Printing thread of this blog, the classifications for our industry are about to be changed to the following lacking any comments to the Office of Budget Management (OMB) as a result of recommendations published in the Federal Register:
- 323113, Commercial Screen Printing
- 323117, Books Printing
- 323119, Other Commercial Printing (except Screen and Books)
Are we really okay with that? Where are our associations in this process? They have not submitted any comments that I can see. This classification puts the bulk of our industry into a classification called "other." How useful can that possibly be? By the way, that includes flexo and gravure printing. You can read the whole document by visiting this link and searching for 323.
We only have until July 12th to provide comments. It's very easy. All you need to do is send an email to [email protected] with the subject NAICS12. Let's not let this roll through unchallenged. Let your voice be heard!
Here are my suggestions, based on product, not process. Maybe they are not the best choices. I hope others will chime in and make them even more representative of our industry today.
- General Commercial Printing
- Packaging Printing
- Publication Printing and Direct Mail
- Book Printing
- Sign and Display Graphics Printing
- Other Commercial Printing (including Letterpress, Blankbook, Looseleaf Binders, and Devices Manufacturing)
Discussion
By Ron Davis on Jul 13, 2010
Dear Carey:
I am replying to your comments on the proposed changes to printing industry classifications by the Census and industry association responses. Printing Industries of America is the only printing industry organization that continuously monitors and interacts with the Census and other Federal statistical agencies such as the Bureau of Labor Statistics concerning printing industry statistical issues. We have communicated both in telephone conversations and in writing to the Census Bureau regarding the proposed changes. We have also worked closely with the Bureau of Labor Statistics over the past few years in regard to occupational classifications and employment patterns in the industry.
Our input to the Census Bureau objected to the proposed changes in NAICS Codes 23110-323122 since it will make it difficult for Printing Industries of America and our members to analyze important changes within the industry. Going from 10 sub-categories to only 3 greatly reduces the level of detail available for analysis. This will reduce the ability to track the segments that are growing vs. declining because a majority of the industry will be aggregated into the new 323119 category. With over 8,000 printer members, the Printing Industries of America represents printers in every segment currently reported in the NAICS system.
Additionally, the consolidation of NAICS codes for the printing industry, along with many other industries, may have an unintended negative consequence. Industry efforts to improve safety and regulatory efforts to enforce compliance could be hampered by dramatic generalization of the industry codes. For example, the consolidation of the NAICS codes will hinder the industry’s attempts for the focused and targeted outreach for compliance and proper dissemination of safety information. With regard to regulatory impacts, data collected and compiled by the Bureau of Labor Statistic’s on injury and illness rates would be substantially ineffective by fact of the broad scope of the data and the limited application of the results.
At the same time Printing Industries of America is the only printing association or printing industry focused research organization that has developed its own statistical tracking of the entire printing industry and sub-sectors. Our independent print market tracking model including our Print market Atlas provides detailed print market sector data on sales, employment and printing plants that is not available from any other source. This ensures that our members have access to detailed accurate data on current industry trends regardless of US Government actions.
While we cannot speak for all trade associations in our industry, we welcome any inquiries about Printing Industries of America’s activities or positions when you are researching a topic of this nature or another of broad industry interest so that your readers have a full picture at the time of publication.
I hope this information clarifies our activities in this area. Please let me know if you have any questions.
Thank you,
Ron
Dr. Ronnie H. Davis
Vice President & Chief Economist
Printing Industries of America
200 Deer Run Road
Sewickley, PA 15143
[email protected]
P 434-591-0527
F 434-589-9603
www.printing.org
By Cary Sherburne on Jul 13, 2010
Thanks, Ron. I wonder if you are willing to share the categories you suggested to the Census Bureau in these discussions.
I am glad your Association is taking some action here. Since the deadline for comments to the Federal Register publication has now passed, it will be interesting to see what they ultimately decide to do. You raise excellent points.