CRN: Ethical conduct rule change would discriminate vs trade associations
In a letter to the Office of Government Ethics, CRN’s government relations vice president Mike Greene takes issue with amendments to proposed regulation (RIN 3209-AA04) published on September 13 that would prevent federal employees from attending events hosted by trade associations that are also registered lobbyists.
He said: “Government employees tasked with promulgating regulations undoubtedly benefit from attending programs where they can learn about the latest scientific developments, see new products and ingredients on the market and understand how industries might be impacted by rulemaking and guidance.
“At the same time, trade association members have the opportunity to learn more about agencies’ interests and processes and are better prepared to comply with federal regulations.”
Trade associations should be exempt
Moreover, educational and professional development programs conducted by trade associations were “virtually indistinguishable from those conducted by the other types of organizations listed as exempt in the proposed rule”, noted Greene.
“They offer the same benefits to government employees and should qualify for the same exclusion.”
The CRN, like many other trade associations, held several educational events that federal employees would be prohibited from attending were the rule to be adopted, he said.
“Trade associations are among the many types of nonprofit organizations that sponsor programs of interest to government employees. They hold seminars, conferences, trade shows, webinars and other events on regulatory issues, science, education, and industry performance.”
Free attendance permitted if gov’t employee speaks at trade association event
The OGE has stipulated that government employees will be allowed to accept free invitations at events where they are speaking or presenting information on behalf of the administration.
However, theimplicationthat trade associations would use such invitations “as a means of cultivating access by registered lobbyists makes it unlikely federal employees would pay out of pocket to attend these types of programs and events, even if they would benefit from attending”, claimed Greene.
“There are countless examples of legitimate, substantive trade association programming that intersect with the government’s interests.
“In order to work together, we need the administration to recognize associations as something more than lobbying groups working to exert undue influence over federal agencies and their employees.”
