ILMA Supports STLE in Opposing OMB’s Proposed Revisions to the Uniform Guidance for Federal Grants
ILMA has submitted a comment letter in support of the Society of Tribologists and Lubrication Engineers (STLE) opposing several provisions of the Office of Management and Budget’s (OMB) Notice of Proposed Rulemaking to revise the Uniform Guidance governing federal grants and cooperative agreements (2 CFR Part 200; 91 FR 32198).
In the comment letter, ILMA highlighted that the success of manufacturing members is inseparable from innovation in tribology research. The letter states:
“Advances in lubrication science, surface engineering, and friction reduction translate into real-world gains in energy efficiency, manufacturing productivity, and transportation performance. Innovation and technological development also play a critical role in helping formulators adapt to increasing regulatory pressures, as the pool of available chemical inputs continues to narrow.”
Key Concerns
- Pre-Issuance Political Review. The proposed rule would require political appointees to screen every discretionary award against undefined criteria, reducing merit-based peer review to an advisory role.
- At-Will Termination and Suspension. The proposed provisions would permit agencies to terminate active awards with minimal explanation, destabilizing ongoing research programs and the broader research architecture — including lab infrastructure, student appointments, project timelines, and capital commitments.
- Organizational Activities. Requiring case-by-case federal pre-approval for conference attendance, publication charges, and membership dues would impose administrative burdens that impede the knowledge transfer between the research community and the practitioners and manufacturers who apply it.
Overall, ILMA shares STLE’s concern that the uncertainty introduced by these proposed changes risks deterring highly qualified researchers from pursuing federal funding — with downstream consequences for the applied science that the lubricants industry depends upon.
Workforce Implications
ILMA also shared concerns about the chilling effect that research instability could have on workforce interest in the field, emphasizing the Association’s efforts to attract talent to the lubricants industry:
“ILMA recently launched its Move the World Forward campaign to energize the next generation of lubrication professionals. A grant system characterized by unpredictability and broad discretionary authority risks undermining that effort, deterring talented students and early-career scientists from pursuing pathways in tribology and lubrication engineering at precisely the moment the industry is working to attract them.”
OMB will now consider public comments before finalizing the rule. ILMA anticipates broad opposition to the proposal and will continue to monitor developments.
Read ILMA’s comment letter here.
