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Testimony Before the U.S. Department of Labor July 20, 2001 This testimony is on behalf of the International Union, United Automobile, Aerospace and Agricultural Implement Workers of America, UAW and its 1.3 million active and retired members. Equally important, this testimony is on behalf of tens of millions of American workers exposed to ergonomic hazards who are not represented by a labor union. We are here to try to put the pieces back together, and restore the faith of our members that the Labor Department intends to protect them against injury at work. That faith was shaken on March 20, when President Bush signed the Congressional resolution of disapproval which wiped out ten years of effort to establish an ergonomic standard. The Senate on March 6, and the House on March 7 had voted against protecting workers from ergonomic injuries, as they had in the past. The difference in 2001 was that the White House for the first time would not back up the safety and health professionals at OSHA. The day after the House vote, a UAW ergonomics technician, from Local 651 in Flint, told me that people came up to her on the plant floor to ask “Does this mean we will lose our ergonomics program?” The issue was raised in local union meetings as well. She is a local expert on how government works, having testified at the OSHA ergonomics hearings in Washington last year. She told our members, “We aren’t going to lose ergonomics, it’s in our contract. We are the UAW and we aren’t going backwards, ever.” However, since ergonomics protections, and the pain and suffering of workers have been denigrated by the national leaders of business, and because the manufacturing economy is slowing, even the UAW will have trouble moving forward. And, our management colleagues in the safety and health profession, who often work side by side with union representatives, have had the legs cut out from under them. There is little my brief time today can add to the information the UAW presented at the OSHA hearings. The UAW presented testimony at three sites. Presenters included 11 local union representatives from automobile industry facilities; nine local union representatives from other sectors, including parts suppliers, agricultural implement, truck, appliances, joint ventures, private sector clerical and public employees; the UAW co-project manager for ergonomics for each of the three auto collective bargaining departments presenting the joint program at that company; and three Health and Safety Department representatives. These authentic shop-floor representatives told about their own injuries, but more importantly, how they had succeeded in protecting themselves and others from future risks. The UAW also submitted over 200 pages of written testimony and commentary as well as training materials and ergonomics manuals developed by the joint UAW-company programs. (The UAW notes that the jointly developed and validated UAW-GM Risk Factor Checklist was recognized by OSHA as a valid means of evaluating ergonomic risk factors.) The experiential data and practical experience presented by local union representatives and staff, the cries for help from victims, and even the comments of our industry colleagues in opposition, are rarely available to an agency or to the public through the published literature. And those workers also stood up to the trick questions and bluster from industry lawyers, and added more information to the record. The evidence in the OSHA record is crucial to the practical validation and application of biomechanical and epidemiological analyses in the real world. The OSHA process thus created a large and valuable new base of data. The hearing record added to information and recommendations collected through years of stakeholder meetings prior to issuance of the proposal, the opinions gathered in the Small Business Review, the best practices conferences held by OSHA, the NIOSH 1997 compendium of all extant research, the 1999 National Academy of Sciences Review. Since the standard was issued, we have seen the 2001 Institute of Medicine review, the issuance of the ACGIH Hand Activity Level Threshold Limit Value and proposed lifting limits. And, if it survives a threatened industry SLAPP suit against the National Safety Council, we may soon see the ANSI Z-365 standard for ergonomics programs issued. UAW members assemble vehicles and make parts for the Big 3 auto makers, and also produce 18-wheelers, construction equipment, locomotives and the Space Shuttle. Their employers are industrial giants. We also represent nearly 300,000 employees of 1500 private and public employers in 2800 bargaining units whose average size is 100. In addition, our units include warehouses, schools, cafeteria workers, health care and social service agencies. These statistics demonstrate the depth and range of the UAW’s experience with ergonomics programs in both manufacturing and non-manufacturing sectors. The UAW’s extensive experience with ergonomics programs answers the questions: Is an OSHA ergonomics standard needed? Is there sound science to support an ergonomics standard? Is an ergonomics standard consistent with industry practice? Is an ergonomics standard feasible? Is an ergonomics standard applicable and feasible in all sectors of the economy? The answer to each of these questions is a resounding “yes.” The actions such a standard would require are not only feasible, they are already commonplace in hundreds of UAW-represented workplaces. The UAW strongly supported OSHA’s ergonomics program standard as a modest, but critical, first step toward abating the largest single cause of injury and disability among American workers generally, and UAW members in particular. The OSHA rulemaking provided an oasis of science amid a desert of lobbying and sound bites. Then, the logic of power overwhelmed the power of logic, and the rule in place was repealed. We are here to argue that the Bush Administration, having eliminated the protections afforded by the ergonomics standard, should mandate that OSHA issue another enforceable ergonomics standard regulation by a time certain. The purpose of federal standards is to codify the practices of industry leaders so that industry followers can adopt those practices while exposing industry laggards and outlaws for what they are. There are literally thousands of consensus safety standards, set by industry to regulate itself. The large majority of OSHA standards are actually outdated, 1970’s vintage consensus standards. OSHA standards, adopted through an open, evidence-rich process, may stretch the industry leaders, but they are particularly hated by the laggards because management has to comply, rather than merely being invited to comply. The UAW testimony today will emphasize the following key points: Each of these points is discussed in detail below: 1. Ergonomics programs are the only means to prevent the majority of injuries suffered by American workers in the automobile industry, and the manufacturing sector generally. Approximately 60% of injuries in the auto sector are muskuloskeletal disorders. The need for ergonomics abatement is most clearly shown in the Bureau of Labor Statistics (BLS) Disabling Injury reports.(1) These studies compile employer-supplied data on the types and causes of injuries and illnesses that result in days away from work. The employer data are a sample of OSHA 101 forms for cases with days away from work. OSHA relied on this same database. We concur with OSHA that these employer-supplied data probably under-report musculoskeletal disorders. However, the data portray the enormity of the problem. In the motor vehicle parts sector (SIC 3714), the employment category of in the auto industry with processes most common to other manufacturing industry and with the most small establishments, 54% of disabling conditions are identified by management as strain or sprain injuries and various cumulative trauma diagnoses which are properly grouped as MSD’s. In addition, about 20% of disabling injuries were in the “other” category, which includes some MSD’s. Therefore, the large majority of disabling conditions are MSD’s. For auto parts, 40% of injuries were coded as arising from repetitive motion or overexertion, with an additional 11% in the “other” category. Back injuries are the largest single diagnosis in this sector, 22%, and shoulder injuries are 7%. Back and shoulder injuries are almost entirely of ergonomic origin. In short, injuries preventable by ergonomics programs dominate the disabling injuries in the motor vehicle parts sector, and manufacturing in general. These data demonstrate that the biggest problems now faced by safety specialists and suffered by workers are hazards that can be abated only by ergonomics programs. 2. Practical ergonomics programs are in place in hundreds of worksites and have set the stage for major progress. Every UAW-represented location in the Big 3 auto companies has a labor-management ergonomics committee in addition to a labor-management health and safety committee. These approximately 300 facilities employ about 350,000 hourly workers and additional salaried personnel, and represent a substantial fraction of the US Gross National Product. The two UAW-represented international transplant assembly plants use the same structure. Labor and management representatives on these committees are trained to analyze injury and illness data to identify high injury jobs; to conduct risk factor analyses; and to identify solutions to reduce ergonomic stresses. Dozens, if not hundreds, of smaller UAW-represented parts suppliers have adopted this model as well. UAW members in the service, clerical and public sectors have been able to implement similar programs. These programs are described in more detail below. The common ergonomic abatement process used by these committees is shown in the accompanying flowchart. Ergonomics is a continuous improvement process with no clear endpoint. In fact, participants believe that ergonomics improvement is integral to a high performance manufacturing system, just as quality improvement is. Initially, these UAW ergonomic programs grew from massive penalty OSHA citations for failure to record injuries and illnesses, and from citations under the General Duty Clause. The programs were later codified in labor contracts. Labor and management representatives argue about the best way to do things and whether change is fast enough, but the need for an ergonomics process on this model is no longer in dispute. Our ergonomics programs have been shown to reduce worker injuries and to increase productivity. 3. The Bureau of Labor Statistics 1998 and 1999 surveys show the effectiveness of UAW-negotiated ergonomics programs. Analysis by the UAW of the most recent government statistics shows that safety and ergonomics programs prevented over 69,000 occupational injuries and illnesses in 1998 in the vehicle assembly and parts sectors. Of these, at least 41,000 were musculoskeletal problems prevented by ergonomics programs. These data are derived from the Bureau of Labor Statistics’ annual injury and illness survey data for 1998, released in December 1999. Reductions in injury rates reported for key UAW workplaces give strong evidence for the effectiveness of UAW safety and health programs generally, and especially for the value of our ergonomics programs. The UAW believes that the motor vehicle assembly (SIC 3711), motor vehicle parts (SIC 3714) and automotive stamping (SIC 3465) sectors have gone farther than most others in implementing ergonomics programs. My testimony concentrates on the auto parts sector. We selected 1994 as the baseline, because that is when ergonomics programs were first likely to be fully implemented, and also to obtain a five year period. For the auto parts sector, the total case rate dropped 12% over one year and 33% over five years, while the occupational illness rate fell 17% over one year and 34% over five years. Cumulative trauma disorders declined 13% and 24% respectively. Over this same period the total case rate, injury rate and CTD rate fell slightly for all private employment, while the illness rate increased by a small amount. The vehicle assembly rate however, dropped 5.5 times as fast as the national average over five years, while auto parts dropped 4.5 times as fast. Percentage reductions were 40% greater in vehicle assembly and 70% greater in parts manufacturing compared to all employers combined. The 1999 data, which did not become available until December 2000, show an additional 5% drop in total rate across the three main auto-related sectors. This evidence of continuing improvement was not included in the record of the OSHA hearings. These data show that ergonomics programs decrease the number of worker injuries, with attendant savings to employers as well. 4. Methods for measuring and relieving ergonomic stresses and procedures for carrying out practical ergonomics programs have been developed and verified over the last decade. The science is well established. The important technical developments for effective ergonomics programs emerged two decades ago, and the broad outline is now largely in place. The driving force was combining the engineering and biomechanics disciplines with medical science and epidemiology. The University of Michigan and NIOSH are the key institutions that have established the United States at the forefront of the science of ergonomics. The technical developments include: Development of consistent methods to measure the physical stresses on the human body. Stress is determined by the force exerted on a body part, the frequency of the motion, and the posture of the joint. The Force-Frequency-Posture paradigm is common to both expert and checklist approaches to ergonomic analysis; Acceptance of expert ergonomic analysis for measurement of risk factors according to these methods; Development of simplified non-expert approaches to measurement of risk factors (checklists); Formulation of the NIOSH lifting guide and related biomechanical models which take into account the weight of an object, distance from the body, and motion of the body in lifting; Validated semi-quantitative risk factor checklists for hand, arm and shoulder (upper extremity) cumulative trauma disorders; Diagnostic criteria for upper extremity CTD’s; Standardized physical examination protocols for upper extremity CTD’s; Validation of symptom surveys and discomfort surveys (psychophysical measures) as risk factor identification tools; Validation of risk factor checklist and symptom survey by workforce personnel to identify high-risk jobs and propose abatement methods; Acceptance of the plant ergonomics committee model, especially lay analysis of risk factors using standardized checklists. These scientific developments rest on an enormous body of published work as well as practical experience. In 1997, NIOSH published a massive compilation of ergonomics studies. The UAW believes that the NIOSH compilation and analysis of virtually all available studies of work-related musculoskeletal disorders settles the question whether there is sufficient science underlying ergonomics. The studies show exposure-response relationships for ergonomic stress factors and musculoskeletal disorders of each body part. NIOSH did an excellent evaluation of hundreds of reports to show the weight and strength of the evidence for cause and effect relationships, and conclusively confirmed that increased stress causes increased injury. Nonetheless, Congress subsequently funded a review of this issue by the National Academy of Sciences.(2). A steering committee was established in May 1998, under the auspices of the NAS Committee on Human Factors. NAS studies typically consist of literature reviews and presentations at open meetings, followed by a report drafted by the expert committee and reviewed by the Academy members and other peer reviewers. The ergonomics study involved an open workshop attended by 66 leading technical experts. The UAW participated in this workshop(3), presenting evidence of our experiences with ergonomics programs. The NAS issued a report on the study in 1999. The summary conclusion was: “Scientific research clearly demonstrates that effective work place interventions are available which can reduce ergonomic hazards and prevent musculoskeletal disorders. There is evidence that interventions are cost-beneficial for employers.” The report thus validated the scientific conclusions cited by OSHA as the basis for its decision to move forward with an ergonomic standard. In 1998, Congress commissioned a second NAS study of the same issues. The second study, discussed below, reached the same conclusions. This section has summarized the state of knowledge when the ergonomics standard was proposed and the hearings began. Below we discuss subsequent scientific developments that further support the need for an ergonomics standard. 5. The principal need over the next decade is accelerating abatement of exposure to physical stresses. Many case histories show improved health outcomes on jobs where risk factors had been reduced. Many facilities report reduced injury rates after implementing ergonomics programs. Scientific studies show reduced injury rates and symptom complaints after job changes. These case studies were reported in the NIOSH conference and are regularly presented at professional meetings. The data presented above show sector-wide reductions in MSD rates in the sector with the most advanced ergonomics activities. These successes are reasons for government to keep pressure on employers to abate ergonomic hazards. The principal problem plant ergonomics committees report is not being able to get high-risk jobs fixed in a timely fashion. High-risk jobs are jobs where injuries have already been recorded. Solutions are usually identified directly from the risk factor analysis: the job task must be changed to reduce the force, limit the number of repetitions of the same motion, or allow the worker to do the job in a neutral posture. Routine solutions include raising loads off the floor with lift tables, adjusting the height of work, reducing the reach to get or place parts, damping vibration, placing the tool or the work in a fixture, reducing or counterbalancing tool weight. Many tricks of the trade are known to engineers and workers alike. People from the workplace know job changes that will allow the work to be done and reduce the stresses. Virtually all these solutions improve quality and efficiency and therefore increase productivity. Nevertheless, to solve ergonomics problems and to reduce injury rates in the long term, an employer has to invest time and money up front. Unless pressure for job improvement is maintained, employers will resist accepting their responsibility. The principal improvement in ergonomics programs achieved in the 1999 round of auto contract negotiations was adoption of specific time limits for the job improvement cycle. In all three auto agreements, management committed that a job will be analyzed within two months of the report of a work-related musculoskeletal disorder and modified to abate identified risk factors within six months of completion of the analysis. In addition, design criteria for new equipment are incorporated into the joint new equipment safety reviews. Some of these criteria are available to suppliers over the internet. 6. The UAW has developed and implemented an ergonomics model for small manufacturing suppliers and office and professional facilities that demonstrates that ergonomics is necessary and feasible in such facilities. These programs also establish industry recognition of MSD risk factors and the elements of a program needed to protect employees. The UAW has implemented ergonomic interventions at approximately 45 smaller UAW-represented worksites over the past five years. The optimal intervention involves all the elements of the OSHA standard, except that MSD management typically falls short of the OSHA proposal. The essential element of the intervention is training a worksite ergonomics committee to analyze jobs and suggest interventions. In UAW-represented facilities, this training is primarily conducted by peer trainers, called Local Union Discussion Leaders (LUDL’s). LUDL’s are full-time employees at UAW-represented facilities. They are shop floor employees who move into a trainer position because of their interest and demonstrated training skills. These persons are released from work on union leave at UAW request to conduct training- related activities. LUDLs assigned to ergonomics training are usually ergonomics committee members at their home facility. They have all taken at least a 40-hour course, conducted job analyses, received training technique instruction and been fully evaluated by UAW Staff and University of Michigan training evaluation staff. Our experience with this training method indicates that because it is based on hands-on activities, it ensures retention of information. The small group discussion and problem-solving allows for direct learning from peers with experience in the topic. The training includes extensive case studies through the use of videos. In addition, it is delivered at the site. It includes a component where participants evaluate real jobs on the shop floor, in real time. The UAW has implemented successful ergonomics programs using this training at numerous small businesses, including Jaquith Industries (Local Union 1128) in Syracuse, New York. With the completion of a recent 40-hour Practical Ergonomics Training (PET) program, Jaquith workers are now able to evaluate problem jobs and develop solutions. Some jobs in this shop are presently being re-engineered to eliminate job hazards. In a recent letter to the UAW Health and Safety Department from Jaquith’s owners, they praised and credited UAW’s Health & Safety Department grant staff for a professional job in helping them to assess their ergonomics concerns and offering solutions to the problems they faced. Other small employers who have worked with the UAW to establish successful ergonomics programs include: Recycle Ann Arbor (Local Union 157) in Ann Arbor, Michigan; Bosch Braking Systems (Local Union 2155) in Johnson City, Tennessee; United Defense Systems (Local Union 683) in Minneapolis, Minnesota; Sidler Corporation (Local Union 417) in Madison Heights, Michigan; and AP Parts (Local Union 12) in Toledo, Ohio.
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