"This document was published prior to the publication of OSHA's final rule on Ergonomics
Program (29 CFR 1910.900, November 14, 2000), and therefore does not necessarily
address or reflect the provisions set forth in the final standard."
Charles N. Jeffress
National Coalition on Ergonomics
U.S. Chamber of Commerce
April 23, 1998
- Today is St. George's Day. St. George is the patron saint of England, and legend has it
that he slew a vicious dragon to win freedom for his nation. St. George's task seemed
impossible. But it was clearly necessary, and he succeeded.
- Although our foesworkplace injuries and illnessesare a far cry from dragons, our task
seems no less daunting. Nevertheless, I am equally determined that we will succeed.
- OSHA's mandate is to assure the safety and health of more than 100 million workers at 6
million sites. Yet there are only about 2,000 federal and state OSHA inspectors. So what
we lack in personnel we must make up for in creativity. We must find innovative ways to
serve as catalysts for improving safety and health in the workplace. We must motivate
others to be aggressive about protecting workers, even if they never see an OSHA
- Through the reinvention efforts of Joe Dear, supported by President Clinton and Vice
President Gore, OSHA has embraced the idea that it's time to change ourselves. We
know we need to operate differently to make a greater impact on workplace safety and
health. And we are doing that.
- We now have a specific plan to focus our effortsa five-year strategic plan to reduce
injuries and illnesses in the workplace. I am committed to following that blueprint as my
management plan for OSHA.
- I am enthusiastic about OSHA's plan because we have zeroed in on the bottom
linepreventing injuries, illnesses and deaths in the workplacerather than on counting
activities. Yes, we'll still take note of how many inspections we do, how many
consultations employers receive and how many standards we issue. Activities are
important, but what really matters are results.
- Over the next five years, we will help employers in 100,000 workplaces where we will
initiate a major intervention to reduce their injury and illness rates by 20 percent. We're
also striving for a 15-percent reduction in injuries and illnesses among five high hazard
industriesfood processing, nursing homes, shipyards, logging and construction. And
we're seeking a 15-percent reduction in three specific injuries and illnessessilicosis,
amputations and lead poisoning.
- Perhaps even more important than the specific injury and illness targets is our goal of a
permanent culture change. We need to make safety and health programs part and parcel
of the work environment in America. When we do that, we know we can prevent injuries
and illnesses not just for a short period after an OSHA inspection, but on into the future.
Safety and health programs keep a good thing going.
- But it looks like we still have some folks who aren't sold on the value of safety and health
programsincluding a number here at 1615 H Street. As a result, we've recently taken a
few steps backward. A critical component of our efforts to reduce injuries and illnesses is
our new Cooperative Compliance Program, announced last November. In CCP, OSHA
has developed an innovative and creative strategy that will benefit employers, employees
- Unfortunately, CCP is on hold right now as the result of a judicial stay. The challenge to
CCP brought by the U.S. Chamber of Commerce will not be resolved until early next
year. So, we've moved to Plan B.
- Last week, we launched our interim inspection targeting system. We've begun
comprehensive inspections at more than 100 workplaces across the country. The initial
inspection pool includes about 3,300 companies in 99 industries with lost workday injury
and illness rates higher than the average for their specific industry.
- So, for the moment, OSHA is headed back to the future. We now have a ground-breaking, old-fashioned inspection program in place. It's a step forward and a step back
at the same time.
- We're moving forward because now that we have worksite-specific data, we can zero in
on those individual employers with the highest injury and illness rates for their industries.
But, because of the lawsuit, we've been forced to take a step back on the promise of
partnership and the opportunity to multiply our impact that CCP offered.
- I'll be frank. This approach is second-best. But it's a necessary step. We must protect
worker safety and health while we defend CCP -- our common-sense partnership strategy -- in court. We didn't want to return to an outdated, traditional enforcement program, but
the lawsuit has left us no choice.
- Let me explain why I've been so excited about CCP, and why we're determined to put it
in place once we're vindicated in court.
- Through CCP, OSHA can direct help to the companies that need it the most. We can
leverage our resources, reaching three times as many worksites.
- In the past, we used Bureau of Labor Statistics data and identified high hazard industries.
That was a good start. But we've known for a long time that we needed to do better. We
essentially held a lottery, and a small percent of employers in high hazard industries won
an inspection. The problem, of course, was that we didn't know which specific
employers really needed our help.
- OSHA's data initiative changed all that. Last year, we surveyed 80,000 employers in
manufacturing and 14 additional high hazard industries. We identified 12,000 specific
worksites in 400 four-digit SIC codes that had experienced at least twice the average rate
of injuries and illnesses.
- Through CCP, we said to those employers, "You're on our list. We plan to inspect
everyone on our list. However, for those employers who promise to implement or
improve their safety and health program, we'll put you on a secondary list with only a 30
percent chance of inspection."
- Employers recognized it as a good deal, and more than 10,00087 percentsigned up.
But their opportunity to test our new partnership has been postponed as OSHA has been
forced to delay its promise. Companies have told us they are disappointed, but they will
still live up to their commitment to improve safety and health programs.
- The CCP issue has been much more contentious than I ever imagined it could be. But we
haven't given up. And we expect CCP to be affirmed by the court.
- On the regulatory front, we are developing a safety and health program standard. That is
one of my top standard-setting priorities. Before I leave office, I want an effective safety
and health program to become a fundamental responsibility of every employer in the
- Our proposed safety and health program standard will incorporate five key elements:
management leadership; employee participation; hazard assessment; hazard prevention
and control; and information and training. And it will be flexible, with appropriate
expectations for companies of different sizes in different industries. We hope to have a
proposal out for comment later this year.
- On that note, let me mention an important safeyt and health program concern you may not
have thought of. As businesses gear up to solve their Year 2000 computer problems, you
need to keep safety systems in mind as well. Apparently, computer chips with timing and
reporting capabilities that are embedded in safety systems can fail just as those powering
mainframes and PC's can. Business Week reported recently that Phillips Petroleum
experienced a shutdown in a hydrogen sulfide monitor system when the company ran a
Y2K test on one of its oil and gas production platforms. Whoever would have thought
that a chemical monitoring system might fail because of a Y2K problem? Like Phillips,
you need to check for potential Y2K problems in your safety systems as well.
- Of course, the issue that concerns all of us here today is musculoskeletal disorders.
Developing an ergonomics standard is also a top priority. I think we need a standard.
And I think we can put one together that will reduce pain and disability, without costing
employers an arm and a leg.
- Nearly one of every four illnesses and lost-time injuries in 1995 resulted from repetitive
motion or overexertion. That's more than 642,000 cases.
- The financial cost is staggeringone of every three dollars in workers' compensation
costs. That's $20 billion in direct costs. Indirect costs could add as much as $100 billion
- As you know, Congress has prohibited us from issuing a proposal before October 1,
1998. However, we can research one, and we are doing that. We're planning a program-oriented standard, based on sound ergonomic principles and focused on serious problems
for which effective solutions can be devised.
- We're planning a focused standard under the umbrella of general industry. And, in this
first phase, we're going to draw the lines narrowly.
- Our economists are poring over the injury and illness data to pinpoint the operations, the
jobs and the tasks where there are high rates of work-related musculoskeletal disorders.
But high rates aren't the whole story. Our ergonomics proposal also will focus on
situations where successful solutions have been identified for particular operations.
- We held a series of stakeholder meetings in Washington in early February to share our
preliminary thinking with business, labor and those in the safety and health field. Some
of you were there. Notes from those meetings have been posted on our ergonomics web
page. And we will have a draft proposal to share with stakeholders at meetings the first
week of June in Portland and Kansas City. We're looking forward to getting your
comments on that document.
- The Coalition has been helpful in our discussions on ergonomics in pointing out the need
for flexibility. A standard calling for two-hour limits on tasks, maximum weights or
minimum breaks doesn't make sense. And we're not going to propose one.
- One thing that hasn't been helpful, however are misleading statements, such as this one
from your website, "The regulations would force unproven and financially prohibitive
changes onto every private employer in the nation. Yet despite the billions of dollars it
would cost, the proposed ergonomic regulation won't necessarily mean a single prevented
workplace injury or illness."
- You know this isn't true -- most, if not all, of you have taken steps that have changed your
workplaces for the better. And the policies you've set and adjustments you've made in
work stations and work practices have prevented injuries. And many have saved money
as well. You know that. So your public statements don't match your companies' actions -- or
your results! I challenge you to make your rhetoric match your actions.
- We know we need to give other employers the tools to solve the ergonomic problems
they face. We don't need a prescriptive standard, but a descriptive one. We'll be
offering employers a flexible framework, not a fixed formula.
- The famous general, George S. Patton, once said, "Never tell people how to do things.
Tell them what to do and they will surprise you with their ingenuity."
- We know American employers and their workers have a lot of ingenuity because they've
shared their solutions to ergonomic problems with us at our national and regional
effective practices conferences.
- For instance, Red Wing Shoes in Minnesota modified work stations and gave its
employees adjustable chairs. Even though the company added two new plants, workers'
comp costs dropped 75 percent over four years.
- Fieldcrest-Cannon in Columbus, Georgia, cut MSD's from 121 in 1993 to 21 in 1996.
They credit their success to worker involvement in designing systems to limit the need for
workers to bend and reach.
- In North Carolina, Perdue Farms started an ergonomics program in 1991. It was so
effective, the company expanded it to all its plants. Although the average LWDII for
poultry process is about 12, six Perdue plants had no lost time injuries in 1996.
- Lunt Silversmiths in Massachusetts bought lifts so workers would no longer need to carry
dies for silver casting by hand. The result? No more back injuries in the machine room.
- Woodpro Cabinetry in Cabool, Missouri, saved $42,000 in workers compensation costs
by bringing its injury rates down when it changed conveyor levels to reduce worker
reaching and added additional conveyors to limit lifting. This is a significant amount for
a company with about 100 workers.
- These are just a few examples, and many involved solutions that cost very little. In fact,
in one study, nearly half the recommended ergonomic controls cost less than $500 each;
and one-fourth cost less than $100. We are talking about small investments in the
workplace with large potential benefits to workers and employers.
- I can tell you at this point that we expect the ergonomics proposal to include six or seven
basic elements: management commitment and employee participation, training, job
hazard analysis, hazard prevention and control, medical management and program
evaluation. And I can also assure you that employers will have a lot of latitude in
determining what is appropriate for each element in line with the specific situation in
- In addition to developing a standard, we are continuing our outreach and education efforts
through the regional effective practices conferences. We are also continuing inspections.
We have cited employers under OSHA's general duty clause for about 10 years for failure
to protect workers against musculoskeletal disorders in industries where ergonomic risks
represent a clearly recognized hazard.
- In the past 18 months, we've opened 142 inspections involving ergonomics. More than
60 percent have resulted in letters outlining recommendations rather than citations
proposing penalties. About 25 percent of the cases are still open.
- OSHA is committed to leading the world in occupational safety and health. Even though
our task appears to be impossible, we have no intention of giving up, no intention of
slacking off. I like that old saying, "The difficult we do immediately. The impossible
takes a little longer." I think St. George would approve.
- We've set our sights on reducing workplace injuries, illnesses and fatalities. And OSHA
will not be deterred by roadblocks, setbacks or the occasional dragon along the way.