oversight

Worker Protection: Private Sector Ergonomics Programs Yield Positive Results

Published by the Government Accountability Office on 1997-08-27.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                  United States General Accounting Office

GAO               Report to Congressional Requesters




August 1997
                  WORKER
                  PROTECTION
                  Private Sector
                  Ergonomics Programs
                  Yield Positive Results




GAO/HEHS-97-163
      United States
GAO   General Accounting Office
      Washington, D.C. 20548

      Health, Education, and
      Human Services Division

      B-277451

      August 27, 1997

      The Honorable Edward M. Kennedy
      Ranking Minority Member
      Committee on Labor and Human Resources
      United States Senate

      The Honorable Major Owens
      Ranking Minority Member
      Subcommittee on Workforce Protections
      Committee on Education and the Workforce
      House of Representatives

      Private sector employers spend about $60 billion annually on workers’
      compensation costs associated with injuries and illnesses experienced by
      their employees. The Department of Labor’s Occupational Safety and
      Health Administration1 (OSHA) has estimated that as much as one-third of
      these costs is due to musculoskeletal disorders (MSD), a wide range of
      illnesses and injuries related to repetitive stress or sustained exertion on
      the body.2 Over the last few years, OSHA has tried to develop a workplace
      standard requiring employers to take particular actions to reduce MSDs and
      the contributing workplace hazards (often called ergonomic hazards). But
      there is disagreement about what workplace conditions cause or
      contribute to MSD and what actions employers should take to reduce MSDs.
      A draft standard that OSHA circulated for informal comment in 1995
      generated significant opposition from many employers because they
      believed it required an unreasonable level of effort to identify jobs with
      ergonomic hazards and to reduce these hazards. Others, including labor
      organizations, generally supported the draft standard and believed it was
      consistent with approaches implemented by many employers. Between
      July 1995 and October 1996, a restriction in an appropriations law
      prohibited OSHA from spending appropriated funds to do further work to
      develop a draft standard. The Congress has enacted a modified restriction
      for fiscal year 1998 that prohibits OSHA from issuing a proposed or final
      ergonomics standard during the year, but allows OSHA to develop such a
      proposal in the meantime.

      1
       OSHA was created to carry out the Occupational Safety and Health Act, which declared a national
      policy of ensuring safe and healthful working conditions for every working man and woman. OSHA
      develops and enforces workplace safety and health standards and educates employers and employees
      about workplace hazards.
      2
       MSDs include conditions such as tendinitis, carpal tunnel syndrome, and lower back injuries and can
      happen to workers in a myriad of occupations, such as computer keyboard operators, nursing home
      attendants, and automobile assembly workers. Symptoms of MSDs can include swelling in the joints,
      limited range of motion, numbness or tingling sensations, and loss of strength.



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Despite the controversy surrounding OSHA’s draft standard, some
employers have taken the initiative to address MSDs through the
implementation of ergonomics programs.3 To learn about these programs
and their results, you asked that we (1) identify the core elements of
effective ergonomics programs and describe how these elements are
operationalized at the facility level, (2) discuss whether these programs
have proven beneficial to the employers and employees that have
implemented them, and (3) highlight the implications of these employers’
experiences for other employers and OSHA.

To identify the core elements of effective ergonomics programs, we
conducted a literature review and interviewed experts in the business,
labor, and academic communities with experience in implementing such
programs or expertise in the field of ergonomics. To learn how the
elements of ergonomics programs have been operationalized at the facility
level and determine whether these programs have proven beneficial, we
conducted case studies at selected facilities of five employers,
interviewing pertinent program officials and obtaining program and results
data (app. I details how these facilities were selected and how the case
studies were conducted). Table 1 shows the employers and facilities
selected, their product or service, and their staffing level.




3
 In this report, “ergonomics programs” refers to the set of actions employers are taking to reduce
ergonomic hazards and MSDs. Ergonomics itself is a broader field of study addressing the interactions
among humans, tasks, and the total work environment, which could include other issues, such as
temperature and lighting. Thus, the term “ergonomic hazards” is in a sense a misnomer because, if
conditions are truly “ergonomic,” no hazards should exist. However, we use the term in this report
because it is commonly used and understood by industry, labor, and ergonomic experts.



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Table 1: Employers and Facilities
Selected for Case Studies                                           Facility and
                                    Employer                        location                     Product or service        Staffing level
                                    American Express         Headquarters;                       Financial planning
                                    Financial Advisors, Inc. Minneapolis,                        and other
                                                             Minnesota                           investment services                5,300
                                    AMP Incorporated                Electronic                   Electronic
                                                                    connectors                   connection devices
                                                                    manufacturing                production
                                                                    facility; Tower City,
                                                                    Pennsylvania                                                      300
                                    Navistar International          Truck assembly               Heavy- and
                                    Transportation                  facility;                    medium-duty truck
                                    Corporationa                    Springfield, Ohio            assembly                           4,000
                                    Sisters of Charity              St. Mary’s Regional          Medical and nursing
                                    Health System                   Medical Center and           home care
                                                                    St. Marguerite
                                                                    d’Youville Pavilion;b
                                                                    Lewiston, Maine                                                   780
                                    Texas Instruments               Defense systems              Radar, navigation,
                                                                    and electronics              and missile
                                                                    manufacturing                guidance system
                                                                    facility;                    assembly
                                                                    Lewisville, Texas                                               2,800
                                    a
                                        Navistar is the only unionized facility in our review.
                                    b
                                     The same ergonomics program covers both Sisters of Charity sites. As a result, we refer to these
                                    two operations as a single facility.



                                    To explore the implications of our findings for other employers and OSHA,
                                    we interviewed pertinent officials and obtained information about current
                                    activities from OSHA and selected states that operate their own OSHA
                                    programs4 about how employers and employees can be encouraged to
                                    reduce or eliminate the occurrence of MSDs. We explored the extent to
                                    which these activities responded to employers’ needs as reflected through
                                    the experiences of our case study employers. We also convened several
                                    panels comprising representatives from the business, labor, and academic
                                    communities to obtain their views on the implications of our findings. Our
                                    findings are based on the experiences of five facilities and, as a result, are
                                    not generalizable to all workplaces. For a more detailed discussion of our
                                    scope and methodology, see appendix I.



                                    4
                                     The Occupational Safety and Health Act allows states to operate their own safety and health programs
                                    as long as they are determined by OSHA to be at least as effective as the federal OSHA program, and it
                                    provides for up to 50-percent federal funding (29 U.S.C. 667, 672 (1994)). Currently, 25 states operate
                                    their own programs. Throughout this report, we refer to these programs as state-operated programs.



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                   Experts, research literature, and officials at our case study facilities
Results in Brief   generally agreed that effective ergonomics programs must have the
                   following core set of elements to ensure that ergonomic hazards are
                   identified and controlled to protect workers: management commitment,
                   employee involvement, identification of problem jobs,5 development of
                   solutions (that is, controls) for problem jobs, training and education for
                   employees, and appropriate medical management. The literature identifies
                   a wide array of alternatives through which employers can implement these
                   elements that require varying degrees of effort from employers and
                   employees.

                   Although the ergonomics programs at all of the case study facilities
                   displayed each of these elements, there was often significant variety in
                   how they were implemented. This variety typically resulted from factors
                   such as differences in the facilities’ industries and product line, corporate
                   culture, and experiences during the programs’ evolution. Also, the
                   processes used by the case study facilities to identify and control problem
                   jobs were typically informal and simple and generally involved a lower
                   level of effort than was reflected in the literature. Controls did not
                   typically require significant investment or resources and did not drastically
                   change the job or operation.

                   Officials at all the facilities we visited believed their ergonomics programs
                   yielded benefits, including reductions in workers’ compensation costs
                   associated with MSDs. These facilities could also show reductions in overall
                   injuries and illnesses as well as in the number of days injured employees
                   were out of work; in some cases, however, the number of restricted
                   workdays increased as a result of an increased emphasis on bringing
                   employees back to work. Facility officials also reported improved worker
                   morale, productivity, and product quality, although evidence of this was
                   often anecdotal. Demonstrating overall program performance was
                   complicated by uncertainties associated with determining what types of
                   injuries should be considered MSDs and analyzing the program’s effect on
                   injuries in light of other complicating factors, such as limited information
                   collected by employers on the costs to implement the programs.

                   Our work revealed that positive results can be achieved through an
                   approach incorporating certain core elements that are implemented in a
                   simple, informal, site-specific manner. Federal and state-operated OSHA
                   programs have undertaken a number of initiatives that can provide

                   5
                   A problem job is one where ergonomic hazards—those workplace conditions that may cause
                   MSDs—exist.



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             employers flexibility, consistent with these case study experiences;
             however, questions remain as to whether these efforts alone are sufficient
             to protect employees from ergonomic hazards. Our findings suggest that
             as OSHA proceeds with its efforts to protect workers from ergonomic
             hazards, it may be useful for it to consider an approach that sets a
             framework for a worksite ergonomics program while providing employers
             the flexibility to implement site-specific efforts and the discretion to
             determine the appropriate level of effort to make, as long as the efforts
             effectively address hazards.


             MSDs  as a workplace concern have received increased attention over the
Background   last several years. While there is some debate about what injuries should
             be considered MSDs,6 data from the Bureau of Labor Statistics (BLS) show
             that, in 1995, there were 308,000 cases of illness due to repeated trauma,
             accounting for over 60 percent of all work-related recorded illnesses7 and
             continuing the decade-long increase in illness due to repeated trauma.
             However, the 1995 total was a slight decrease from 1994 and represented a
             small percentage of the total number of recordable injuries and illnesses.
             In 1997, the National Institute for Occupational Safety and Health (NIOSH),
             a federal agency that conducts independent research on workplace safety
             and health issues, reported that, for all cases involving days away from
             work in 1994, about 700,000 (or 32 percent) were the result of repetitive
             motion or overexertion. It also reported that MSDs accounted for
             14 percent of physician visits and 19 percent of hospital stays.

             To protect employees from workplace hazards, OSHA issues workplace
             standards and enforces the provisions of those standards through citations
             issued as a result of on-site inspections of employers. OSHA can also
             provide information and technical assistance or work with employers and

             6
              For example, some employers believe that back injuries, even though they may appear to be acute,
             should be counted as MSDs, since they may actually result from repetitive activity. Others do not
             believe back injuries should be counted as MSDs.
             7
              BLS does not currently have a simple way to classify an injury or illness as an MSD. Instead, MSDs
             either are not classified separately from other injuries or appear in a variety of other categories of
             injuries and illnesses. As a result, there is no single estimate of the total number of MSDs reported. A
             widely used measure of MSDs is what BLS calls illnesses due to “repeated trauma,” which it defines as
             illnesses due to repeated motion, vibration, or pressure (such as carpal tunnel syndrome or tendinitis).
             This category would not include items such as back injuries that may result from overexertion and
             would be classified as injuries rather than illnesses. Concerns have been raised about whether the
             collection and coding of data in this manner accurately capture all MSDs. BLS collects these data
             through its Survey of Occupational Injuries and Illnesses, which is administered to a sample of
             employers. The data for the survey are taken from the employers’ OSHA 200 logs, forms that the
             majority of employers are required to use to record any work-related injury or illness that requires
             more than first aid. The OSHA 200 log also contains information about whether the injury or illness
             resulted in days away from work or whether the employee was assigned to restricted work activity.



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employees in a cooperative manner that rewards compliance instead of
penalizing noncompliance. Because currently no standard exists
specifically for MSDs, federal and state-operated OSHA programs have
generally relied on what is referred to as the “general duty clause” of the
Occupational Safety and Health Act,8 or its state equivalent, to cite
employers for ergonomic hazards. This clause requires employers to
furnish employees with employment and a place of work “free from
recognized hazards that are causing or are likely to cause death or serious
physical harm.” To justify using this authority, OSHA must prove that the
hazard is likely to cause serious harm, that the industry recognizes the
hazard, and that it is feasible to eliminate or materially reduce the
hazard—conditions that require major OSHA resources to demonstrate.9

Over the last several years, OSHA has tried to develop a standard
specifically for MSDs to carry out its mandate to protect workers and
improve worker health. In 1992, OSHA announced in the Federal Register its
intent to develop a standard for MSDs. Before formally proposing a
standard, in March 1995, OSHA circulated a draft of a standard to selected
stakeholders to obtain their comments. The standard was subsequently
distributed widely and has come to be known as the “draft standard.” This
draft standard10 required employers to identify problem jobs on two bases:
where there had been one or more recorded MSD (for example, on the OSHA
200 log or as a workers’ compensation claim) and where an employee had
daily exposure during the work shift to any “signal risk factor.”11
Employers would have to “score” these jobs using a checklist provided in
the draft standard, or an alternative checklist if the employer could
demonstrate that it was as effective, to determine the severity of the



8
 29 U.S.C. 654(a)(1)(1994).
9
 Officials from Labor’s Office of the Solicitor said that relying on the general duty clause as a basis for
citing employers for ergonomic hazards can be time consuming and expensive. It may also have
limited effectiveness for protecting workers from MSDs. For example, in 1988, OSHA cited one
employer for repetitive motion hazards associated with assembly line tasks as well as for unsafe lifting
practices. The employer appealed, and in April 1997, a final ruling found that OSHA appropriately used
the general duty clause to cite the employer for lifting hazards and that assembly line workers were
suffering serious physical harm from recognized ergonomic hazards; the ruling also found, however,
that OSHA presented insufficient proof to demonstrate how the repetitive motion hazard could be
eliminated under the general duty clause. (Pepperidge Farm, Inc., 1997 CCH OSHD 31, 301 (No.
89-0265, 1997)).
10
 The draft standard covered all employers and provided detail on how they should identify and
analyze jobs, implement controls, ensure medical management, and provide education and training.
The draft standard and its several nonmandatory appendixes were several hundred pages long.
11
  OSHA identified five “signal risk factors”: (1) performance of the same motion or motion pattern,
(2) fixed or awkward postures, (3) use of vibrating or impact tools or equipment, (4) using forceful
hand exertions, and (5) unassisted frequent or heavy lifting.


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problem. If a job received more than five points,12 the employer would
have to conduct a job improvement process to address the hazards on that
job. This process involved a detailed job analysis (identification and
description of each risk factor) and the selection, implementation, and
evaluation of controls.13 Some employers opposed this requirement,
stating that the net effect of this approach would result in considering
virtually every job a problem job and necessitating considerable resources
from employers to analyze and develop controls for each problem job.
Others said that because MSDs are cumulative or chronic in nature, they
may take a long time to develop and may have many contributing factors.
Because of this, some employers questioned whether OSHA could
demonstrate that provisions in the standard would be able to address the
hazards that cause MSDs.

OSHA  has now said its 1995 draft standard is no longer under consideration,
and it has renewed efforts to determine the best approach to protect
workers from ergonomic hazards. OSHA is currently undertaking a
“four-pronged approach,” which involves (1) education, outreach, and
technical assistance to employers; (2) research on the effectiveness of
ergonomic improvements that employers have implemented;
(3) enforcement efforts targeted toward high-hazard employers, issuing
citations when warranted under the general duty clause; and (4) continued
work on a standard that will take findings from these efforts into account.14

The California state-operated program also spent several years developing
a standard, which program officials said was initiated in response to a
legislative mandate. The two-page standard, which went into effect in
July 1997, covers only those employers with 10 or more employees, thus
excluding a significant number of California’s employers. The standard is
triggered only when an injury has been reported.15 While the standard
requires employers to implement particular elements of an ergonomics


12
 Points were to be accumulated on the basis of the type of risk and the length of time employees were
exposed to the risk. The workplace environment (for example, lighting and temperature) and control
over the pace of work (such as machine pace, piece rate, constant monitoring, and daily deadlines)
were also factors in accumulating points.
13
 The draft standard also allowed employers to implement an abbreviated “quick fix” approach if the
problem was easily identifiable.
14
 This approach is consistent with OSHA’s draft strategic plan developed under the Government
Performance and Results Act. The plan calls for a comprehensive strategy to identify workplace safety
and health problems that combines common sense regulation; a firm, fair, and consistent enforcement
policy; and new approaches to compliance assistance to meet the needs of workers and employers.
15
 The standard applies only when at least two recorded repetitive motion injuries—another term for
MSDs—have been reported within the previous 12 months by employees performing identical job
processes or operations. These injuries must also be diagnosed by a physician as being work related.


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                         program, such as worksite evaluation,16 development of controls, and
                         training, the standard does not require a medical management program,
                         nor are there many requirements as to specifically how these elements
                         should be implemented. An employer who makes an effort to comply will
                         not be cited for being out of compliance unless it can be shown that a
                         control known to, but not taken by, the employer is substantially certain to
                         have caused a greater reduction in these injuries and that this alternative
                         control would not have imposed additional unreasonable costs. Some
                         labor organizations believed this standard fails to provide adequate
                         protection to employees and were skeptical that it would be effective in
                         reducing MSDs. Additionally, even though the standard had been revised
                         significantly to reduce employers’ responsibilities in response to employer
                         concerns,17 some employer groups still question the merit of a standard for
                         MSDs. As a result, both labor and employer groups are challenging the
                         standard.


                         Experts, available literature, and officials at our case study facilities
An Effective Program     generally agreed that, to be effective, an ergonomics program should
Includes a Core Set of   include a core set of elements or provisions to ensure management
Elements                 commitment, employee involvement, identification of problem jobs,
                         development of controls for problem jobs, training and education for
                         employees, and appropriate medical management.18 These core elements
                         are said to be typical of any comprehensive safety and health program and,
                         together, they can help an employer ensure that ergonomic hazards are
                         identified and controlled and that employees are protected. Research
                         provides a wide spectrum of options for how these elements can be
                         implemented, requiring varying levels of effort on the part of employers
                         and employees. In addition, federal and state-operated OSHA programs have
                         undertaken a number of enforcement and education efforts to encourage
                         employers to adopt the core elements of an ergonomics program.




                         16
                           “Worksite evaluation” is the identification and analysis of problem jobs.
                         17
                          Earlier versions of the standard covered virtually all employers in the state and called for them to
                         undertake specific procedures to implement many of these core elements.
                         18
                           Different terminology is sometimes used to refer to these core elements. For example “hazard
                         prevention and control” and “development of controls for problem jobs” can be used to describe the
                         process for analyzing problem jobs and implementing controls. Core elements of safety and health
                         programs are clearly identified in a variety of occupational safety and health literature. A recent
                         NIOSH publication, Elements of Ergonomics Programs, identifies these core elements as they apply to
                         ergonomics programs on the basis of its field investigations. The 1990 Ergonomics Program
                         Management Guidelines for Meatpacking Plants, a voluntary guideline published by OSHA, presents
                         the core elements of an ergonomics program aimed at reducing MSDs in the meatpacking industry.


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Management Commitment       Occupational safety and health literature stresses that management
                            commitment is key to the success of any safety and health effort.
                            Management commitment demonstrates the employer’s belief that
                            ergonomic efforts are essential to a safe and healthy work environment for
                            all employees. Specific ways in which management commitment can be
                            demonstrated include

                        •   assigning staff specifically to the ergonomics program and providing time
                            during the workday for these staff to deal with ergonomic concerns;
                        •   establishing goals for the ergonomics program and evaluating results;
                        •   communicating to all staff the program’s importance, perhaps through
                            policy statements, written programs, or both; and
                        •   making resources available for the ergonomics program itself, such as by
                            implementing ergonomic improvements or providing training to all
                            employees or to staff assigned to the ergonomics program.


Employee Involvement        Involving employees in efforts to improve workplace conditions provides a
                            number of benefits, including enhancing employee motivation and job
                            satisfaction, improving problem-solving capabilities, and increasing the
                            likelihood that employees will accept changes in the job or work
                            methods.19 Some of the ways in which employee involvement can be
                            demonstrated include

                        •   creating committees or teams to receive information on ergonomic
                            problem areas, analyze the problems, and make recommendations for
                            corrective action;20
                        •   establishing a procedure to encourage prompt and accurate reporting of
                            signs and symptoms of MSDs by employees so that these symptoms can be
                            evaluated and, if warranted, treated;
                        •   undertaking campaigns to solicit employee reports of potential problems
                            and suggestions for improving job operations or conditions; and



                            19
                               NIOSH’s Participatory Interventions in Meatpacking Plants concluded that strong management
                            support and staff expertise in team building and ergonomics are needed for participatory efforts to
                            work. In Occupational Safety and Health: Options for Improving Safety and Health in the Workplace
                            (GAO/HRD-90-66BR, Aug. 24, 1990), we found that strengthening the role of both employers and
                            employees in identifying and correcting workplace hazards was a viable strategy to improve workplace
                            safety and health.
                            20
                              Concerns have been expressed by employer groups as well as by labor organizations that electing
                            employee representatives to workplace committees, including those committees formed by
                            management to address ergonomic issues, could violate a prohibition of the National Labor Relations
                            Act against employers’ controlling labor organizations (29 U.S.C. 158 (a)(2)). This issue was outside
                            the scope of this review.



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                            •   administering periodic surveys to obtain employee reactions to workplace
                                conditions so that employees may point out or confirm problems.


Identification of Problem       A necessary component of any ergonomics program is the gathering of
Jobs                            information to determine the scope and characteristics of the hazard that
                                is contributing to the MSD. Especially in this element, research has
                                highlighted a wide variety of ways employers can identify problem jobs or
                                job tasks. For example, a relatively straightforward way to identify
                                problem jobs is for employers to focus on those jobs where there is
                                already evidence that the job is a problem, because MSDs have already
                                occurred or symptoms have been reported. For this approach, employers
                                could use the following methods to identify problem jobs:

                            •   following up on employee reports of MSDs, symptoms, discomfort, physical
                                fatigue, or stress;
                            •   reviewing the OSHA 200 logs and other existing records, such as workers’
                                compensation claims; and
                            •   conducting interviews or symptom surveys or administering periodic
                                medical examinations.

                                A more complex approach to identifying problem jobs before there is
                                evidence of an injury entails employers’ looking for workplace conditions
                                that may contribute to MSDs. This more complex method could include
                                screening and evaluating jobs for particular workplace conditions that
                                may contribute to MSDs, such as awkward postures, forceful exertions,
                                repetitive motions, and vibration. Screening and evaluation could be
                                achieved through walk-through observational surveys, interviews with
                                employees and supervisors, or the use of checklists for scoring risk
                                factors.

                                Experts and recent literature also recognize that employers may have to
                                prioritize which jobs or job tasks will receive immediate attention. It is
                                generally agreed that jobs in which MSDs are being reported should be
                                given top priority. Factors to consider in prioritizing problem jobs might
                                be whether past records have noted a high incidence or severity of MSDs,
                                which jobs have a large number of affected employees, or whether
                                changes in work methods for that job will be taking place anyway.


Analyzing and Developing        The first step in eliminating the hazard is to analyze the job or job task to
Controls for Problem Jobs       identify the ergonomic hazards present in the job. Once ergonomic



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    hazards have been identified, the next step is to develop controls to
    eliminate or reduce these hazards. Research offers a hierarchy of controls
    that can be put in place.

    Analyzing the job or evaluating an employee’s workstation to identify the
    ergonomic hazards present in the job can involve a variety of activities,
    including

•   observing workers performing the tasks, interviewing workers, or
    measuring work surface heights or reach distances;
•   videotaping a job, taking still photos, measuring tools, or making
    biomechanical calculations (for example, of how much muscle force is
    required to accomplish a task) in order to break jobs down into
    component tasks and identify risk factors present; and
•   administering special questionnaires.

    Efforts to develop appropriate controls can include

•   “brainstorming” by employees performing the job in question or by team
    members performing the analysis;
•   consulting with vendors, trade associations, insurance companies,
    suppliers, public health organizations, NIOSH, labor organizations, or
    consultants; and
•   following up to evaluate the effectiveness of controls.

    The hierarchy of controls is as follows:

•   Engineering controls are generally preferred because they reduce or
    eliminate employees’ exposure to potentially hazardous conditions. They
    include changing the workstation layout or tool design to better
    accommodate employees (for example, adopting better grips for knives to
    reduce wrist-bending postures) or changing the way materials, parts, and
    products are transported to reduce hazards (such as using mechanical
    assist devices to lift heavy loads).
•   Administrative controls21 refer to work practices and policies to reduce or
    prevent employee exposure to hazards, such as scheduling rest breaks,
    rotating workers through jobs that are physically tiring, training workers




    21
     Some of the literature identifies training and similar activities related to proper work techniques as
    “work practice controls.” For ease of discussion in this report, we refer to them as administrative
    controls as well.



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                             to recognize ergonomic hazards, and providing instruction in work
                             practices that can ease the task demands or burden.22


Training and Education       Identifying and controlling MSDs requires some level of knowledge of
                             ergonomics and skills in remedying ergonomic hazards. Recognizing and
                             filling different training needs is an important step in building an effective
                             program. The different types of training that a facility might offer include

                         •   overall ergonomics awareness training for employees so they can
                             recognize general risk factors, learn the procedures for reporting MSDs or
                             symptoms, and become familiar with the process the facility is using to
                             identify and control problem jobs and
                         •   targeted training for specific groups of employees because of the jobs they
                             hold, the risks they face, or their roles in the program, such as for line
                             supervisors and managers to recognize early signs and symptoms of MSDs;
                             for engineers to prevent and correct ergonomic hazards through
                             equipment design, purchase, or maintenance; or for members of an
                             ergonomics team to perform job analysis and develop controls.


Medical Management           An employer’s medical management program is an important part of its
                             overall effort to reduce MSDs, even though this program may exist
                             regardless of whether the employer has implemented an ergonomics
                             program. A medical management program emphasizes the prevention of
                             impairment and disability through early detection of injuries, prompt
                             treatment, and timely recovery for the employee. Different ways facilities
                             can carry out medical management include

                         •   encouraging early reporting of symptoms of MSDs and ensuring that
                             employees do not fear reprisal or discrimination on the basis of such
                             reporting;
                         •   ensuring prompt evaluation of MSD reports by health care providers;
                         •   making health care providers familiar with jobs, perhaps through periodic
                             facility walk-throughs or review of job analysis reports, detailed job
                             descriptions, or videotapes of problem jobs; and
                         •   giving employees with diagnosed MSDs restricted or transitional duty
                             assignments (often referred to as “light” duty) until effective controls are

                             22
                               There is some controversy about whether personal protective equipment (controls that provide a
                             barrier between the employee and the hazard) is effective against ergonomic hazards. NIOSH reported
                             that these types of devices may decrease exposure to one hazard but increase another because the
                             employee has to “fight” the device to perform the work (for example, wearing wrist splints while
                             repeatedly bending the wrist). Other studies have found that some of these items, such as back belts to
                             provide back support, do provide protection.



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                         installed on the problem job, and conducting follow-up or monitoring to
                         ensure that they continue to be protected from exposure to ergonomic
                         hazards.


Selected OSHA Efforts    Federal and state-operated OSHA programs have undertaken a number of
Encourage Employers to   enforcement and education efforts to encourage employers to adopt the
Implement These Core     core elements of an ergonomics program. For example, as a result of
                         inspections under the general duty clause, OSHA has entered into a number
Elements                 of corporate settlement agreements, primarily with automobile
                         manufacturing and food processing employers, that allow these employers
                         to take actions to implement these core elements in an effort to reduce the
                         identified hazards according to an agreed-upon timetable. OSHA monitors
                         the employers’ progress under the agreement and will not cite them as
                         long as the terms of the agreement are upheld. In 1996, OSHA introduced a
                         nursing home initiative, under which it targeted nursing homes in seven
                         states for inspection to look for evidence of safety and health programs as
                         evidenced by these core elements. Before launching the enforcement part
                         of the effort, OSHA sponsored safety and health seminars for the nursing
                         home industry to help employers implement safety and health programs.

                         The North Carolina state-operated program makes extensive use of
                         settlement agreements for employers that have been found during
                         investigations to have ergonomic hazards. Under what it calls the
                         Cooperative Assessment Program (CAP) for Ergonomics, employers are not
                         cited for ergonomic hazards if they enter into and make a good faith effort
                         to comply with these agreements, under which they must take actions to
                         implement the core elements of a safety and health program. To help these
                         and other employers learn how to develop programs, the state recently
                         established an ergonomics resources center that provides a variety of
                         ergonomic services to employers.23 The California state-operated program
                         creates joint agreements and “special orders”24 for individual employers
                         when ergonomic hazards are identified during an inspection. These
                         agreements and orders require employers to take corrective action to



                         23
                           This center is operated by the University of North Carolina through a partnership between the
                         University and the state Department of Labor. Established in 1994 with state funding, the center seeks
                         to enroll employers as “members” in an effort to become self-sustaining. The center provides on-site
                         ergonomic evaluations and other services to members. These services are also available to
                         nonmember employers at prescribed fees.
                         24
                          Typically, California will first try to enter into a joint agreement with the employer and will only do a
                         special order when employers do not correct the identified hazards voluntarily under the joint
                         agreement.



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reduce the identified hazards according to a particular timetable; if the
employers take the corrective actions specified, no penalties are assessed.

Instead of using the general duty clause, some states have used existing
regulatory authorities that require employers to establish worksite safety
and health programs, workplace safety committees,25 or both to encourage
employers to address MSDs. These safety and health programs must have
particular elements, such as the identification of problem jobs and
training, and in some cases, the committees themselves are responsible for
undertaking particular activities. For example, in Oregon, workplace
committees are required to conduct particular activities as they relate to
identification of ergonomic hazards.26

Through Cooperative Compliance Programs, federal and state-operated
OSHA programs have targeted certain employers because of their high rates
of injuries or high numbers of workers’ compensation claims and offered
them a chance to work with OSHA to reduce hazards in exchange for not
being inspected. If employers agree, they must implement a program
containing these elements to reduce hazards and injuries. For example, in
the Maine 200 program, about 200 Maine employers were invited to
develop a comprehensive safety and health program to reduce the injuries
and hazards identified by OSHA.27 Employers “graduate” from this program
once they demonstrate that they have successfully implemented the core
elements of a safety and health program, not necessarily because they
have achieved a particular reduction in injuries or hazards.28 Also, OSHA’s
Voluntary Protection Program allows employers to be excluded from
programmed inspections if they can demonstrate they have an exemplary
safety and health program consisting of these core elements.

Federal and state-operated OSHA programs and other organizations also
educate employers about how to reduce MSDs and other safety and health

25
  Since the early 1990s, at least six state-operated programs have legislated requirements for employers
to develop and implement comprehensive worksite safety and health programs. See Occupational
Safety and Health: Worksite Safety and Health Programs Show Promise (GAO/HRD-92-68, May 19,
1992).
26
 Oregon requires committees to review OSHA 200 log data to determine whether MSDs are a problem,
and if so, to take corrective measures.
27
 Although this program did not target MSDs, OSHA officials said they found that a large number of
employers’ workers’ compensation claims were for injuries and illnesses associated with MSDs.
According to officials, this program allowed OSHA to work with employers to address ergonomic
hazards that would not have otherwise received attention. One of the facilities in our review—the
Sisters of Charity facility—participated in this program.
28
  OSHA is attempting to expand Cooperative Compliance Programs into additional federal-jurisdiction
states.



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                        hazards through consultation and technical assistance. The services are
                        typically coordinated by federal or state-operated programs but are
                        actually delivered by state government agencies, universities, or
                        professional consultants. Consultation programs allow employers to
                        contact OSHA or its designee to identify and address safety and health
                        problems outside the enforcement arena. If employers address the hazards
                        identified by these consultants, they can be exempt from inspections for
                        up to 1 year. The consultation and technical assistance services provide
                        information on how to develop effective safety and health programs. A key
                        document used in the provision of these services is OSHA’s Safety and
                        Health Program Management Guidelines, which provides information on
                        how to implement a safety and health program (although it does not
                        include a medical management component).29 Additionally, because of
                        high rates of MSDs in the meatpacking industry, in 1990 OSHA published the
                        Ergonomics Program Management Guidelines for Meatpacking Plants, a
                        voluntary set of guidelines on how to implement the core elements of an
                        ergonomics program in that industry.


                        Each of the facilities we visited displayed all of the core elements of an
Facilities Have         effective ergonomics program, but the facilities implemented them in a
Implemented Core        variety of ways that reflected their unique characteristics, such as their
Elements in a Variety   different industries and product lines, corporate cultures, and experiences
                        during program evolution. For example, although each facility
of Ways                 demonstrated management commitment by assigning staff to be
                        specifically responsible for the program, some facilities used ergonomists
                        to lead the program, while others used standing teams of employees. For
                        two of the elements—identification of problem jobs and development of
                        controls—the facilities displayed a lower level of effort than many of the
                        options identified in the literature would entail. To illustrate, the facilities
                        primarily identified jobs on an “incidence basis,” that is, on the basis of
                        reports of injury, employee discomfort, or other employee requests for
                        assistance, and did not typically screen jobs for ergonomic hazards. The
                        facilities also used an informal process to analyze jobs and develop
                        controls, often relying on in-house resources, and did not typically
                        conduct complex job analyses. Finally, facilities typically implemented
                        what they called “low-tech” controls, those solutions that did not require
                        significant investment or resources, as opposed to more complex controls

                        29
                          Other public and private sector groups provide education and assistance as well. For example, the
                        American National Standards Institute, a private organization that oversees the development of
                        industry consensus standards, is currently working on a voluntary standard for how employers can
                        implement these core elements to reduce MSDs. NIOSH recently issued guidelines on the elements of
                        ergonomics programs as well as a review of the epidemiologic research on the relation between
                        selected MSDs and exposure to physical factors at work.



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                            that drastically changed jobs or operations. Following are selected
                            examples of facility experiences for each of the elements; for more
                            information on how all of the facilities demonstrated these elements, see
                            appendixes III through VII.


Program Evolution and       All of the facilities’ programs had evolved over time—often over many
Other Factors Have          years—and a number of factors were key to facilities’ decisions to take
Influenced Implementation   actions to reduce MSDs.30 Primary among them was an interest in reducing
                            the workers’ compensation costs associated with MSDs.31 Additionally, the
of Elements                 variation in implementation was often explained by industry type, product
                            lines or production processes, corporate cultures, or experiences during
                            program evolution. For example, most of the employees at the
                            headquarters of American Express Financial Advisors, a financial services
                            employer, are engaged in similar operations that require significant use of
                            computers, so they face similar hazards associated with computer use.
                            Because of this similarity, the cornerstones of the ergonomics program are
                            training for all employees on how to protect themselves from these
                            hazards and developing furniture and equipment standards, which is
                            accomplished by involving such departments as real estate and facilities.

                            Facility product lines, production processes, and other individual facility
                            characteristics also affected implementation of the elements. For example,
                            the Navistar facility’s layout has constrained the implementation of some
                            controls. Additionally, Navistar offers customized truck assembly, which
                            often contributes to frequent production and schedule changes. This
                            makes it difficult to ensure that controls are effective in the long run.
                            Finally, because few new employees have been hired in recent years, the
                            facility now has an older workforce that could be more vulnerable to these
                            types of injuries.

                            Corporate culture may also influence program development. Both AMP’s
                            and Texas Instruments’ corporate cultures emphasize decentralized
                            operations whereby individual facilities are given considerable flexibility
                            to reach production goals. Local employee teams are key to their


                            30
                              As a result, officials could not readily identify a date when their programs “began,” but rather when
                            the programs were “fully implemented.” See app. I for the years these facilities’ programs were fully
                            implemented.
                            31
                              According to our analysis of workers’ compensation data from each of the facilities, MSDs accounted
                            for about 50 percent or more of their total annual workers’ compensation costs for the earliest
                            implementation year for which we had data. Four of the five facilities in our review operated on a
                            self-insured basis, which some experts believe may make it easier for employers to be aware of total
                            workers’ compensation costs.



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                               operations because they allow for this type of decentralized approach. As
                               a result, the facilities rely extensively on employee teams to implement
                               their ergonomics programs. Texas Instruments has a number of teams
                               throughout its management structure, which address ergonomics in some
                               aspect. Additionally, performance targets drive all corporate and facility
                               activities at Texas Instruments, so these kinds of targets have also been
                               established for the facility’s ergonomics program.

                               Experiences during program evolution also have influenced the ultimate
                               shape of the program. At the Texas Instruments facility, where the
                               ergonomics program has been in place the longest (since 1992), the facility
                               is beginning to identify problem jobs on a more proactive basis given that
                               many problem jobs identified on an incidence basis have already been
                               addressed. The Sisters of Charity facility, which initiated its program in
                               1994 at the invitation of OSHA to participate in the Maine 200 program, is
                               still principally working to control problem jobs as a result of employee
                               requests. In addition, because this facility was selected for the Maine 200
                               program on the basis of its injuries of all types, it set up a safety and health
                               program that addresses MSDs as well as other injuries and illnesses.


Management Commitment          All of the facilities had assigned staff to be specifically responsible for the
Is Demonstrated by             program and had provided them the resources, time, and authority to
Assigning Staff to Be          operate the program on a daily basis. Some of the other indicators of
                               management commitment were incorporating ergonomic principles into
Responsible for the            corporationwide accountability mechanisms, such as strategic goals or
Ergonomics Program             safety audits, and integrating ergonomic principles into equipment
                               purchase and design. Although some of the facilities had a written
                               program, officials did not view these as key to program operations and
                               said that management commitment was best illustrated in more tangible
                               ways, such as assigning staff to ergonomics programs or incorporating
                               ergonomics into accountability measures. The examples below highlight
                               some of the variety in the ways management commitment was
                               demonstrated and generally reflect the range of activities that appears in
                               the literature.

Assigning Staff Specifically   The American Express Financial Advisors facility has an ergonomist who
Responsible for Ergonomics     leads the program, an ergonomics specialist who performs the workstation
                               evaluations and develops controls, and a half-time administrative assistant
                               who tracks information about what types of training and ergonomics
                               services each employee has been provided. The AMP facility uses an
                               ergonomics value-added manufacturing (VAM) team of line employees who



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                                 are responsible for identifying problem jobs and developing controls. The
                                 Texas Instruments facility has both an ergonomics team and an
                                 ergonomics specialist who works under the direction of the team.

Establishing Goals and           The Texas Instruments facility works toward a corporationwide strategic
Accountability Mechanisms        goal of eliminating all preventable occupational and nonoccupational
                                 injuries and illnesses by the year 2005, a goal toward which ergonomic
                                 activities at all facilities are expected to contribute.32 At the Navistar
                                 facility, the 5-year strategic plan sets targets for the number of processes
                                 to be redesigned ergonomically, the percentage of technical support staff
                                 to receive ergonomic training, and the reduction in lost workdays and
                                 associated workers’ compensation costs.

Integrating Ergonomic            At the Sisters of Charity facility, the on-site occupational health clinic must
Principles Into Equipment        approve any new construction to ensure that new work areas are designed
Design                           with ergonomic considerations. At the American Express Financial
                                 Advisors facility, the ergonomist works with several departments involved
                                 with procurement to establish standards for purchasing furniture and
                                 equipment that are ergonomic.

Making Resources Available for   At the AMP and Texas Instruments facilities, most of the suggestions for
the Program                      controlling problem jobs submitted by the ergonomics teams are approved
                                 at the facility level.33 The American Express Financial Advisors facility
                                 provides weekly 1-1/2-hour training sessions that are open to all
                                 employees. Sisters of Charity spent about $60,000 to purchase 14
                                 automatic lifts to reduce ergonomic hazards associated with moving
                                 residents at the nursing home.

Ensuring That Middle             The Texas Instruments facility’s Site Safety Quality Improvement Team
Management Support Is            (QIT), which is composed of program managers, provides overall focus and
Sustained                        strategy to the ergonomics team and approves most capital investments to
                                 improve ergonomic conditions. Twice in 1996, the facility sponsored
                                 “Ergonomic Management Seminars” for middle managers to demonstrate

                                 32
                                   Beginning in 1996, Texas Instruments established a yearly target of a 20-percent reduction from the
                                 previous year’s number of injuries and illnesses and number of cases with lost or restricted workdays.
                                 Although only 1 year into this goal, the Lewisville facility achieved its 1996 target. However, concerns
                                 have been raised by labor representatives about whether the incorporation of such objectives into
                                 facility safety goals or managers’ performance evaluations discourages employees from reporting
                                 injuries and discomfort.
                                 33
                                   Several of the facilities require cost justifications for these controls; in most cases, these
                                 justifications are required for all capital investments, not just for ergonomic investments. At two of the
                                 facilities, only when the cost of the controls surpasses a certain threshold ($1,500 at Texas
                                 Instruments; $2,000 at AMP) is a written cost justification required in order to get approval. When
                                 developing these cost justifications, the AMP team uses estimates of the costs of future MSDs should
                                 the suggested control not be implemented.



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                                how ergonomically related losses affected the bottom line by discussing
                                the costs of these injuries and their impact on productivity.


Employee Involvement            Employee involvement at these facilities was often demonstrated through
Demonstrated Through            the use of employee teams or committees charged with identifying
Teams, Direct Employee          problem jobs and developing controls for them. In addition, employees
                                had direct access to services; for example, some facilities had procedures
Access to Ergonomic             that ensured a job analysis was done upon employee request. The
Services                        examples below highlight some of the variety of ways that these facilities
                                fostered employee involvement and generally reflect the range of activities
                                that appears in the literature.

Creating Committees or Teams    The AMP facility’s ergonomics VAM team consists of about 12 employees
                                from different departments who meet biweekly during work hours. This
                                team, led by an industrial engineer, is responsible for identifying and
                                prioritizing problem jobs as well as for developing controls for the jobs.
                                Both the team leader and secretary of the team are elected by the team
                                members. Individual team members play leadership roles in
                                “championing” various projects. At the Navistar facility, the ergonomist
                                and local union representative form the nucleus of the ergonomics
                                committee, with other employees involved on an ad hoc basis to provide
                                information and feedback for the particular problem job being addressed.

Establishing Procedures So      At the Navistar facility, any employee can request a job analysis by filling
Employees Can Directly Access   out a one-page “Request for Ergonomic Study” form and passing it along to
Ergonomic Services              the ergonomist or the union representative. At the American Express
                                Financial Advisors facility, employees can request a workstation
                                evaluation through a phone call, by E-mail, or even by scheduling an
                                evaluation themselves on the ergonomics specialist’s electronic calendar.

Administering Surveys and       American Express Financial Advisors’ discomfort surveys help the
Conducting Campaigns            ergonomics staff identify areas of concern for employees as well as the
                                type of discomfort employees are feeling in various body parts. The Texas
                                Instruments facility sponsors “wing-by-wing” measurement campaigns in
                                which the team proceeds through the facility “wing by wing” to measure
                                employees and adjust the workstations of those who may be experiencing
                                problems but who have not requested services.


Simple, Incidence-Based         All of the facilities in our review identified most of their problem jobs on
Process Used to Identify        an “incidence basis,” that is, from reports of MSDs or employee discomfort
Problem Jobs                    or as the result of an employee request for assistance. The procedures


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                                 instituted for identifying problem jobs in this way were typically quite
                                 simple, with little paperwork involved. In most cases, only after problem
                                 jobs identified on an incidence basis were dealt with did officials at these
                                 facilities report they used more “proactive” methods to identify problem
                                 jobs where injuries might occur in the future. While the facilities used a
                                 variety of proactive methods for identifying problem jobs, they did not
                                 typically screen jobs for risk factors. Therefore, we characterize the
                                 facilities’ efforts to identify problem jobs as a lower level of effort than is
                                 reflected in the literature. The examples below highlight some of the ways
                                 facilities carried out this lower level of effort.

Identifying Problem Jobs on an   All facilities had a system in place whereby any report of an MSD
Incidence Basis                  automatically triggered a job analysis. At the Sisters of Charity facility, the
                                 employee and supervisor must each complete a “Report of Employee
                                 Incident” form within 24 hours after an MSD is reported. This form is sent
                                 to staff at the on-site occupational health facility who conduct a physical
                                 examination of the employee, if necessary, and an evaluation of the
                                 employee’s workstation. A job analysis was also generally triggered
                                 whenever an employee reported discomfort or requested assistance. At the
                                 AMP facility, employees are encouraged to bring up any discomfort they are
                                 feeling with members of the ergonomics team. The Texas Instruments
                                 facility identified problem jobs on the basis of the high numbers of injuries
                                 and illnesses recorded in its workers’ compensation database.

Identifying Problem Jobs on a    Because the Texas Instruments facility had already addressed many of the
Proactive Basis                  hazards at its manufacturing workstations, it launched an administrative
                                 workstation adjustment campaign in recognition of its need to shift its
                                 focus to identify potential hazards at administrative workstations. The
                                 Navistar facility has begun to identify problem jobs as those with high
                                 employee turnover and those staffed by employees with low seniority. The
                                 AMP facility uses an Ergonomic Prototype Work Center to set up
                                 alternative types of workstations in order to determine the best types of
                                 tools to use and the most efficient workstation layouts to avoid future
                                 injuries.


Informal Process Used to         All of the facilities in our review used a simple, fairly informal procedure
Analyze Problem Jobs and         to analyze problem jobs, as compared with some of the more complex
Develop Controls                 options detailed in the literature. Often the facilities’ efforts focused only
                                 on the particular job element that was thought to be the problem (for
                                 example, drilling or lifting). Facilities also said the process for developing
                                 controls was informal, relying heavily on brainstorming and the use of



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                               in-house engineering and medical resources. In some cases, facilities did
                               conduct a detailed job analysis when the problem job was particularly
                               complex, hazardous, or labor intensive. Also, while typically able to
                               develop controls using in-house resources, the facilities on occasion used
                               consultants and other external resources to develop controls for problem
                               jobs.

                               The process used to develop controls was typically iterative, in that the
                               ergonomics staff at these facilities continually reviewed the job in question
                               to ensure that the control was working. In some cases, eliminating the
                               hazard would have been difficult without significant capital investment in
                               a soon-to-be-phased-out product or without disruption to the production
                               process. In other instances, even when a control was identified, resource
                               limitations sometimes extended the length of time it took to introduce the
                               control. However, officials emphasized that they always tried to take some
                               kind of action on all problem jobs.

                               Facilities used a mix of the controls described in the literature in their
                               attempts to eliminate or reduce ergonomic hazards for problem jobs,
                               generally preferring “low-tech” engineering controls—those that did not
                               require significant capital investments and did not drastically change the
                               job’s requirements. The examples illustrate the processes used by these
                               facilities to identify problem jobs and the types of controls used. Appendix
                               II profiles particular problem jobs at these facilities and the controls that
                               were implemented.

Analyzing Jobs Through         The AMP facility uses a one-page “Ergonomic Evaluation Form” that is
Observation, Interviews, and   tailored to the specific job and asks simple “yes/no” questions about the
Measurements                   employee’s ease and comfort when performing certain job tasks. After
                               reviewing this form, a member of the ergonomics VAM team interviews the
                               employee and observes the employee performing the job.34 The
                               ergonomics specialists at the American Express Financial Advisors and
                               Texas Instruments facilities take workstation and personal measurements
                               (for example, height of work surface and height of chair when seated
                               properly), in addition to making observations or collecting information
                               from employees through interviews.

                               For more complex or hazardous jobs, facilities may videotape or collect
                               more detailed documentation. The AMP facility videotaped its re-reeling job

                               34
                                As an incentive for employees to complete the form, the facility allows those who do so to try out any
                               new tools or equipment and help decide what equipment or tools should be purchased. Officials also
                               said the current form had been simplified to encourage employees and members of the ergonomics
                               VAM team to complete it.



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                            and used an additional evaluation form, which is several pages long, that
                            provides space to record detailed observations about the adequacy of the
                            work space, environmental conditions, and hand tool use. A physical
                            assessment survey capturing the frequency of discomfort by various body
                            parts was also conducted because the re-reeling department historically
                            had higher numbers of MSDs. The Texas Instruments facility videotaped its
                            manual electronic assembly job because it had identified this as an
                            “at-risk” job—that is, one with high numbers of recordable injuries and
                            illnesses. (See app. II for more detailed information.)

Developing Controls by      Officials at all of the facilities said brainstorming was key to developing
Brainstorming and Using     controls. At the Navistar facility, for example, the ad hoc committee
In-House Resources          informally develops prospective solutions and looks at other operations
                            within the facility with similar job elements to get ideas for controls.
                            Facility officials at Texas Instruments also said that, in addition to their
                            own employees and line supervisors, their production engineering
                            department was also a resource for developing controls on more complex
                            or technical jobs.

                            In other instances, outside resources were important contributors to
                            developing effective controls. For example, the AMP facility regularly
                            works out arrangements for vendors or suppliers to provide tools and
                            equipment at no cost to the facility so the facility can test the products
                            before purchasing them. Through AMP’s Ergonomic Prototype Work
                            Centers, which are set up within each work area, these tools are then
                            evaluated by the employees themselves in alternative workstation layouts.
                            The Texas Instruments facility has used a consultant to help develop
                            controls for its at-risk jobs, including its manual electronic assembly job.
                            Because recommendations for controls came from the consultant, the
                            ergonomics team found it was easier to get management buy-in to make
                            the necessary job changes. (See app. II.)

Developing Controls Is an   Ergonomics staff assess how well a control is working and, if necessary,
Iterative Process           continue to address the problem job. At AMP, the ergonomics VAM team
                            administers the same Ergonomic Evaluation Form that is administered
                            when first analyzing the job after the controls are in place to determine
                            whether or not they are working. At the Texas Instruments facility, an
                            adjustable-height workstation design was tested on the production floor,
                            and employee feedback revealed that it was unstable and allowed
                            products to fall off. Using this feedback and working with a vendor, the
                            ergonomics staff developed a new design. The result was an adjustable




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                       table, referred to as “Big Joe” (essentially a fork lift with the wheels
                       removed), which proved to be much more stable.

                       Because the Navistar facility is still not satisfied with controls introduced
                       to address its “pin job,” which it described as its most onerous job, it also
                       is taking an iterative approach. The pin job requires several employees to
                       manually handle the heavy frame of a truck in order to attach it to the
                       axle. Because of the significant force, “manhandling,” and vibration
                       involved, the ergonomics staff has focused considerable effort on
                       controlling this job. However, changing the product and the line is difficult
                       to justify, given constraints associated with the facility’s design. In the
                       meantime, facility officials have tried to reduce employees’ exposure using
                       administrative controls and personal protective equipment and have
                       recently formed a special committee of line employees to develop ideas
                       for controls for this job. According to Navistar Officials, this committee
                       has been given 6 months, an “unlimited” budget, and the latitude to
                       consider alternative design options for the production line.

                       In some cases, facilities made efforts to ensure the long-term effectiveness
                       of controls they had implemented. For example, both the Texas
                       Instruments and American Express Financial Advisors facilities had
                       developed databases that contained the results of workstation evaluations
                       and employee preferences. At both of these facilities, employees are
                       relocated frequently, so the information in the databases is used to ensure
                       that, when an employee is relocated, his or her new workstation will be
                       properly set up.

Focus on Low-Tech      The Navistar facility installed hoists to lift heavy fuel tanks and
Engineering Controls   mechanical articulating arms to transport carburetors. It is gradually
                       replacing “impact” guns—which are used to drill in bolts—with
                       “nutrunner” guns, which expose employees to lower levels of vibration.
                       American Express Financial Advisors has adjusted employee workstations
                       (for example, repositioned monitors, designed corner work surfaces, and
                       provided equipment to support forearm use) and introduced ergonomic
                       chairs for employees’ use. (For more detail, see app. II.)

                       Facilities also used administrative controls, particularly for problem jobs
                       where they have been unable to eliminate the ergonomic hazards through
                       engineering controls. For example, in the re-reeling job at the AMP facility,
                       employees are rotated every 2 hours so they are not reeling the same
                       product over long periods of time. The Texas Instruments facility also uses
                       job rotation to protect circuit board welders from ergonomic hazards and



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                             other administrative controls rather than major investments, particularly
                             when the product is soon to be discontinued. Some of the facilities also
                             used personal protective equipment; for example, the Navistar facility has
                             made extensive use of such equipment as padded gloves and elbow
                             supports to provide protection and absorb vibration.


Training Generally           Some of the facilities provided general awareness training to all
Targeted to Specific         employees, but this information was generally offered informally through
Groups of Employees          written employee guidelines, posters, literature, and web sites. Most of the
                             facilities emphasized training targeted to specific populations of
                             employees. Examples below highlight some of the ways in which facilities
                             provide training and education and were generally consistent with the
                             literature.

General Awareness Training   Not every facility offered formal general awareness training to all
                             employees. For those that did, such training was brief and sometimes
                             offered infrequently. For example, at Sisters of Charity, ergonomics
                             training in the form of body mechanics and instruction on the proper use
                             of video display terminals was offered as part of the 4-1/2-hour basic safety
                             training that each employee is required to take once a year. At the Texas
                             Instruments facility, all employees are required to take 1 hour of general
                             ergonomics awareness training every 3 years.

Targeted Training            Training is the cornerstone of the American Express Financial Advisors
                             ergonomics program, where the ergonomics specialist teaches a 1-1/2-hour
                             course every week targeted to the many computer-oriented jobs at this
                             facility. Employees are generally required to take this training before their
                             workstations will be adjusted. Personal measurements are taken during
                             training, and participants are taught how to make their workstations fit
                             their needs. The Texas Instruments facility offers a wide range of targeted
                             training, with an emphasis on instruction of production teams within their
                             own work areas in which team members actually work together to develop
                             controls for problem jobs. Courses offered at the facility include
                             “Ergonomics for Computer Users,” “Factory Ergonomics Awareness,” and
                             “Advanced Ergonomics for Electronic Assemblers and Teams That Handle
                             Materials.”




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                                   B-277451




Ergonomics Programs                The ergonomics programs at these facilities had strong links with the
Strongly Linked to Medical         medical management staff35 in ways that were consistent with the
Management Programs                literature. For example, a report of an MSD automatically triggered a job
                                   analysis; medical management staff were often members of the
                                   ergonomics teams; and medical management staff were also familiar with
                                   jobs at the facility, which helped them identify the hazards to which
                                   employees were exposed. The facilities also emphasized a return-to-work
                                   policy that gave employees with diagnosed MSDs the opportunity to work
                                   on restricted or transitional (sometimes referred to as light duty)
                                   assignments during their recovery period. Facilities also conducted
                                   follow-up during the time an employee was on restricted duty. Examples
                                   below highlight some of the ways these facilities demonstrated this
                                   element.

Encouraging Early Reporting        The Navistar facility has an on-site occupational health clinic and medical
and Ensuring Prompt                management staff who are easily accessible to all employees and who can
Evaluation                         treat most injuries, including MSDs. The medical director can request a job
                                   analysis whenever an employee reports an injury or discomfort to the
                                   clinic. The medical director participates on Navistar’s ad hoc ergonomics
                                   committee to help develop controls for problem jobs and on the facility’s
                                   workers’ compensation causation committee, which looks for the root
                                   cause of selected workers’ compensation claims.

Making Health Care Providers       The American Express Financial Advisors facility has established a
Familiar With Jobs                 relationship with several local health care providers who are familiar with
                                   MSDs and has encouraged these health care providers to visit the facility to
                                   understand the jobs its employees perform. These health care providers
                                   provide early treatment to avoid unnecessary surgery, which is sometimes
                                   called conservative treatment. At Texas Instruments, the disability
                                   coordinator is responsible for developing a relationship with local health
                                   care providers and identifying doctors who are conservative in their
                                   treatment approach.

Using Transitional or Restricted   At the Texas Instruments facility, the lost time intervention manager
Duty to Return Employees to        monitors health conditions of out-of-work employees and coordinates
Work and Conducting                with all other medical management staff to determine if the employee can
Follow-Up                          return to work on a restricted basis. Typically, the employee can be
                                   accommodated within his or her home work area. Several things have
                                   been done to facilitate these placements, including developing a database

                                   35
                                     Medical management staff can include on-site doctors and nurses, workers’ compensation staff
                                   (including staff responsible for monitoring lost time and workers’ compensation costs), disability
                                   coordinators, and off-site health care providers. Not every facility has all of these staff, and facilities
                                   may share these staff with other facilities owned by the same company.



                                   Page 25                                     GAO/HEHS-97-163 Private Sector Ergonomics Programs
                           B-277451




                           of available jobs for workers on restriction and creating a special account
                           that covers the payroll costs of employees on transitional duty so the costs
                           are not charged to that home work area’s budget. If the limitations are
                           permanent and prohibit the employee from performing essential job
                           functions with reasonable accommodation, the employee is referred to the
                           Texas Instruments placement center for job search and other placement
                           assistance.


                           Officials at all the facilities we visited believed their ergonomics programs
Ergonomic Programs         brought benefits, including reductions in workers’ compensation costs
Bring Benefits,            associated with MSDs. These facilities could also show reductions in
Although                   facilitywide overall injury and illness incidence rates,36 and in the number
                           of days injured employees were away from work, although some facilities
Measurement                reported an increase in the number of days employees were on restricted
Problems Exist             job assignments. Facility officials also reported improved worker morale,
                           productivity, and quality, although evidence of this was sometimes
                           anecdotal. However, measuring program performance—assessing these
                           outcomes in light of program efforts—was complicated by uncertainties
                           associated with determining which injuries should be included as MSDs and
                           with tracking changes in those injuries in light of complicating factors. For
                           example, facilities did not track the total costs of their ergonomics
                           programs so they could not assess whether benefits gained exceeded the
                           investments made. As a result, these employers found it helpful to track
                           the progress they were making in implementing the program.


Facilities Have Realized   All five facilities experienced a reduction in total workers’ compensation
Reduction in Costs of      costs for MSDs (see fig. 1). Reductions are not comparable across facilities,
MSDs                       but officials at each of these facilities said they believed the facility’s
                           ergonomics program had contributed toward these reductions. At the
                           Texas Instruments facility, where the ergonomics program has been in
                           place for the longest period of time, workers’ compensation costs for MSDs
                           have dropped appreciably—from millions of dollars in 1991 to hundreds of
                           thousands of dollars in 1996. The achievement of these reductions is
                           significant, given that high MSD costs were a major impetus for initiating
                           these programs and lowering these costs was often a major outcome goal.




                           36
                             The incidence rate is the number of injuries and illnesses for every 100 full-time employees per year.



                           Page 26                                   GAO/HEHS-97-163 Private Sector Ergonomics Programs
                                     B-277451




Figure 1: Percentage Reduction in
Workers’ Compensation Costs for      100       Percentage Reduction
MSDs at the Case Study Facilities                                                  91


                                               80

                                       75

                                                        62       61



                                       50


                                                                          35


                                       25




                                        0
                                                  (19viso s
                                                      92 rs
                                                             )

                                                             )



                                                             )




                                                  (19yste y
                                                      94 m
                                                             )

                                                      91 ts
                                                             )
                                                         /96

                                                         /96



                                                         /96




                                                         /96


                                                         /96
                                                           s




                                                           t
                                                 h S ari



                                                  (19men
                                                l A pre



                                                      93



                                                      93



                                              alt Ch
                                           cia Ex



                                                   19



                                                  (19
                                                    d




                                                  tru
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                                               P(
                                        an an




                                              ns
                                             tar
                                          AM
                                     Fin eric




                                           sI
                                          ter
                                         vis




                                        xa
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                                     Am




                                      Na




                                     Te




                                    Facility



                                     Notes: Data are not adjusted for inflation. Years typically represent the year before full
                                     implementation of the program for each of the facilities compared with 1996. Exceptions are
                                     described in app. I.

                                     American Express Financial Advisors’ workers’ compensation database operates on a policy year
                                     basis, which is from Sept. of one year through Sept. of the next. In other words, policy year 1991
                                     is Sept. 30, 1991, through Sept. 29, 1992. For clarity of discussion, we refer to policy year 1991 as
                                     “1992”; policy year 1992 as “1993”; and so on. Also, workers’ compensation data are not available
                                     for headquarters only (the facility we visited). Data represented here are for all of American
                                     Express Financial Advisors. However, most of the employees work in the headquarters office.

                                     For yearly data, see apps. III through VII.

                                     Source: GAO analysis of case study facilities workers’ compensation databases.




                                     These reductions can be attributed to a strong medical management
                                     component in the ergonomics program. As the medical director of the
                                     Navistar facility explained, the key to a cost-effective ergonomics program
                                     is getting injured employees back to work as soon as appropriate,
                                     minimizing lost workdays. Officials at several of the facilities said one of
                                     their first activities when implementing this program was to assist



                                     Page 27                                   GAO/HEHS-97-163 Private Sector Ergonomics Programs
B-277451




employees in returning to work. As figure 2 shows, the facilities were able
to reduce the number of days injured employees were away from work.
Conversely, restricted work days increased at facilities owned by AMP and
Sisters of Charity, which officials said reflected their success at bringing
employees back to work. This reflects an important challenge to a
return-to-work policy, however, because bringing employees back to work
as soon as possible may require a greater number of available restricted-
or light-duty positions than are often available. For example, according to
Navistar officials, light-duty positions for returning employees must be
allocated according to the seniority provisions of the collective bargaining
agreement, so if an injured employee does not have sufficient seniority,
there may not be any light-duty jobs available. Or, the jobs available to less
senior employees, such as clean-up duty, are often not appealing to
employees who desire productive work. Sisters of Charity officials said
they do not have difficulty finding light-duty jobs for employees, but there
have been cases in which employees’ restrictions were so severe that it
was difficult for these employees to be productive.




Page 28                        GAO/HEHS-97-163 Private Sector Ergonomics Programs
                                     B-277451




Figure 2: Change in Lost and
Restricted Workdays for Case Study   Number of Days per 100 Full-Time Workers per Year
Facilities                            50                                                      45


                                      25             21


                                       0


                                      -25
                                                                                                                   -15

                                      -50                                    -35       -35


                                      -75
                                                                                                          -66
                                            -78
                                     -100


                                     -125
                                                                   -122
                                     -150

                                               AMP (1993/96)         Navistar            Sisters of         Texas
                                                                     (1993/96)           Charity Health     Instruments
                                                                                         System             (1991/96)
                                                                                         (1993/96)
                                               Facility



                                                          Lost Work Days

                                                          Restricted Work Days



                                     Notes: Years typically represent the year before full implementation of the program for each of the
                                     facilities compared with 1996. Exceptions are described in app. I. As a financial institution, the
                                     American Express Financial Advisors facility is not required to maintain an OSHA 200 log, so it
                                     did not have the information available to calculate lost and restricted workdays. As a result, it is
                                     not included in this figure.

                                     For data used for calculations, see apps. IV through VII.

                                     Source: GAO analysis of case study facilities’ OSHA 200 logs.




                                     Medical management also includes encouraging employees to report
                                     symptoms of MSDs before they become serious injuries requiring more
                                     expensive treatment or surgery; as a result, reductions in the average cost
                                     per claim reflect early reporting and treatment. The Sisters of Charity
                                     facility was the only facility that had not yet experienced a decline in the




                                     Page 29                                       GAO/HEHS-97-163 Private Sector Ergonomics Programs
                                  B-277451




                                  average cost per claim (although this cost is well within the range of the
                                  average cost per MSD claim at other facilities).37 (See fig. 3.)


Figure 3: Average Cost per MSD
Workers’ Compensation Claim for   25000     Average Dollar Cost per MSD Claim
Case Study Facilities
                                                                                                                             21946


                                  20000




                                  15000




                                  10000     9123                                    9518


                                                               6601
                                                                                                                                      5322
                                                                                             4860
                                   5000
                                                                                                               3014
                                                                         2512                           2469
                                                     1685

                                       0

                                             American            AMP (1993/96)        Navistar            Sisters of          Texas
                                             Express                                  (1993/96)           Charity Health      Instruments
                                             Financial                                                    System              (1991/96)
                                             Advisors                                                     (1994/96)
                                             (1992/96)
                                             Facility



                                                      Before Ergonomics Program Fully Implemented

                                                      After Ergonomics Program Fully Implemented



                                  Notes: Data are not adjusted for inflation. Years typically represent the year before full
                                  implementation of the program for each of the facilities compared with 1996. Exceptions are
                                  described in app. I.

                                  American Express Financial Advisors’ workers’ compensation database operates on a policy year
                                  basis, which is from Sept. of one year through Sept. of the next. In other words, policy year 1991
                                  is Sept. 30, 1991, through Sept. 29, 1992. For clarity of discussion, we refer to policy year 1991 as
                                  “1992”; policy year 1992 as “1993”; and so on. Also, workers’ compensation data are not available
                                  for headquarters only (the facility we visited). Data represented here are for all of American
                                  Express Financial Advisors. However, most of the employees work in the headquarters office.

                                  Source: GAO analysis of case study facilities’ workers’ compensation databases.




                                  37
                                    Sisters of Charity officials said the increase was primarily due to a high-cost claim that involved a
                                  large number of lost workdays.



                                  Page 30                                    GAO/HEHS-97-163 Private Sector Ergonomics Programs
                                        B-277451




                                        These facilities could also show reductions in the number of injuries and
                                        illnesses for their facilities as a whole, according to their OSHA 200 log
                                        records (see fig. 4). Trends in overall injuries and illnesses from the OSHA
                                        200 log are important because MSDs accounted for a large portion of all
                                        injuries and illnesses and because these data are part of the information
                                        OSHA compliance officers review in the early stages of an inspection to
                                        focus their inspection efforts.


Figure 4: Reduction in Injury and
Illness Incidence Rates at Case Study   7.0     Reduction in Number of Injuries and Illnesses per 100 Full-Time Workers
Facilities
                                                                 6.1
                                        6.0     5.7


                                        5.0

                                                                                          4.0
                                        4.0


                                        3.0
                                                                               2.4

                                        2.0


                                        1.0


                                          0
                                                   )



                                                                      )




                                                                                     (19yste y
                                                                                          93 m
                                                                                                )

                                                                                          91 ts
                                                                                                )
                                                /96



                                                                 /96




                                                                                            /96


                                                                                            /96
                                                                                              t
                                                                                     h S ari



                                                                                     (19men
                                              93



                                                                 93



                                                                                  alt Ch
                                              19



                                                             (19




                                                                                      tru
                                                                              He s of
                                           P(




                                                                                   ns
                                                           tar
                                         AM




                                                                                sI
                                                                               ter
                                                       vis




                                                                             xa
                                                                       Sis
                                                      Na




                                                                          Te




                                        Facility



                                        Notes: Years typically represent the year before full implementation of the program for each of the
                                        facilities compared with 1996. Exceptions are described in app. I. As a financial institution, the
                                        American Express Financial Advisors facility is not required to maintain an OSHA 200 log, so it
                                        did not have the information available to calculate incidence rates. As a result, it is not included in
                                        this figure.

                                        For data used for calculations, see apps. IV through VII.

                                        Source: GAO analysis of case study facilities’ OSHA 200 logs.




                                        Page 31                                                     GAO/HEHS-97-163 Private Sector Ergonomics Programs
                            B-277451




Gains Have Been Observed    Facility officials also reported improved employee productivity, quality,
in Productivity, Quality,   and morale since they had implemented the programs, although evidence
and Employee Morale         of these outcomes was primarily anecdotal. For example, some facility
                            officials said employees are more likely now to exercise control over their
                            jobs and to be more actively involved with line supervisors in how jobs are
                            performed. Officials from Sisters of Charity believed that turnover and
                            absenteeism had been reduced and they had been able to hire better
                            employees as a result of their efforts, even though employees initially
                            resisted some of the changes proposed, such as the use of automatic lifts
                            to move residents. The American Express Financial Advisors facility
                            reported reductions in discomfort experienced by employees.38

                            Officials at several of the facilities said that as the program evolves, goals
                            need to change as well, from reducing workers’ compensation costs to
                            increasing productivity and quality. For example, officials at the Texas
                            Instruments facility stressed that they were moving toward using
                            productivity and other quality measures as indicators of the program’s
                            success, since they had already achieved large reductions in workers’
                            compensation costs.

                            Facilities also provided evidence, often only anecdotal, of productivity or
                            quality improvements associated with implementing ergonomic controls.39
                            Several facilities have found that ergonomic hazards often contribute to
                            production bottlenecks or problems. By minimizing employees’ stressful
                            hand exertions during a windshield installation process, for example, the
                            Navistar facility was also able to increase the quality of the installation,
                            reducing a high rate of warranty claims (see app. II). Additionally, by
                            identifying a newly automated way of extracting remnant metals when
                            electronic connectors are stamped, the AMP facility not only eliminated
                            awkward positions for employees but also reduced the volume of scrap
                            waste and enhanced the quality of recycled metals made from these scrap
                            metals.




                            38
                              These results are from American Express Financial Advisors’ annual discomfort survey. About
                            three-quarters of employees surveyed experienced headaches and discomfort in the neck and back in
                            1993. As of 1996, only about a third of employees surveyed said they experienced discomfort in these
                            body parts.
                            39
                             Officials at two facilities had concerns that ergonomic controls might not always lead to productivity
                            gains, particularly if they slowed down production processes or spread existing workloads among a
                            greater number of employees. This concern may indicate the need to identify a different control that
                            would address the ergonomic hazard without negatively impacting productivity.



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                         B-277451




Measuring Program        Facility officials said they faced a number of challenges in measuring the
Performance Poses Many   overall performance of their programs and tying outcomes to the efforts
Challenges               they were making in implementing their programs. Primary among these
                         challenges was determining what injuries should be included as MSDs, and
                         effectively tracking the changes in the number and severity of those
                         injuries in light of what officials referred to as “confounding” factors that
                         complicated their ability to interpret outcomes or changes that
                         accompanied their program efforts.

                         Although many of the officials from the facilities said a major influence for
                         initiating the program was a concern about increased workers’
                         compensation costs due to MSDs, in the early stages of implementing the
                         ergonomics programs some of the facilities reported uncertainties about
                         what injuries and illnesses should be categorized as MSDs. American
                         Express Financial Advisors officials said the lack of agreement about MSDs
                         makes it difficult to know what to track when trying to isolate MSDs from
                         other kinds of injuries and illnesses. Sisters of Charity officials said, in
                         many cases, incident reports must be reviewed to identify whether the
                         injury was caused by ergonomic hazards. Ergonomics staff at the facilities
                         said the OSHA 200 log was not very useful to them for identifying MSDs
                         because it does not allow various injuries that they believe are a result of
                         ergonomic hazards to be recorded as such. For example, officials at
                         several of the facilities said that back injuries, which are often a result of
                         repetitive lifting, are not recorded in the OSHA 200 log in a way that they
                         can be identified as MSDs.

                         These employers used their respective corporate workers’ compensation
                         databases to help them identify what types of injuries should be included
                         as MSDs for the program, as well as to track reductions in these injuries and
                         illnesses. Several of the facilities worked with their insurance company, or
                         the administrator of their insurance policy, to help track these injuries and
                         illnesses and related costs. However, because corporate workers’
                         compensation databases included different categories of injuries, and
                         because facilities differed in the frequency and type of injuries
                         experienced, facilities used different categories of injuries to track MSDs.
                         For example, while all of the facilities included injuries or illnesses that
                         resulted from obviously repetitive activity, some also included those that
                         were the result of a one-time occurrence. Differences of opinion also
                         existed in at least one facility between the ergonomist and corporate




                         Page 33                        GAO/HEHS-97-163 Private Sector Ergonomics Programs
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management as to what categories should be included to track MSDs.40
Using cost data, like workers’ compensation costs, to interpret outcomes
is also problematic, because health care costs in general continue to rise
and there is often a several-year lag between the time injuries occur and
when a workers’ compensation claim is finally closed. Such lags, if large,
could make tracking program performance difficult.

Facilities experienced other factors that made it difficult to interpret
outcomes in light of program efforts, including limited data on program
costs, the effects of growing employee awareness of MSDs, changes in
staffing levels, and the effect of increasing workloads. For example,
facilities did not track the total costs of the ergonomics programs, so they
did not know whether the reductions in MSD costs and other outcomes
exceeded program expenditures.41 Facility officials said it was also
difficult to know whether these outcomes resulted solely from
investments taken to reduce ergonomic hazards or from other productivity
and quality investments as well. However, these officials said that many
ergonomic investments were small, and at several facilities, a written
justification was needed only when the cost of proposed controls was over
a certain threshold.42 Despite their strong commitment to their program,
officials at AMP emphasized that the limited number of years of its trend
data makes it difficult to draw any conclusions at this time regarding the
impact of its program.

Facility officials also stated that increases in MSDs and claims, at least
initially, could result from growing awareness of ergonomic hazards. At
the Texas Instruments facility, ergonomics awareness training contributed
to employees’ making more MSD claims in 1994 (see app. VII). MSDs and
workers’ compensation claims can also be affected by changes in staffing
levels, as new employees may be more likely to get hurt, and the threat of
layoffs may encourage employees to report discomfort or injuries. Since
1988, American Express Financial Advisors has experienced significant
increases in staffing levels and workloads, increases that officials said
need to be considered when looking at its claim experience (see app. III).

40
  At the Navistar facility, the ergonomist preferred to track progress by individual injury category (for
example, a back injury or carpal tunnel syndrome) when the contributing ergonomic hazard was direct
(that is, lifting or repetitive activity), while corporate management preferred to track all injuries to
which all types of ergonomic hazards might have contributed.
41
  None of the facilities had cost accounting systems designed to track ergonomic program costs alone.
42
  The Texas Instruments facility estimated that changes to its administrative workstations to control
ergonomic hazards cost on average only $15 to $20; changes to manufacturing workstations were on
average $50 to $1,000. However, in some cases, these expenditures were more significant, like the
$60,000 spent by the Sisters of Charity facility on 14 lifts for nursing home attendants to use to move
residents.



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                               Other facility officials said claims tend to increase before a layoff, then
                               decline again when employees are recalled to work. Workload pressures
                               and other work organization factors can also affect program outcomes.43
                               Several facility officials said issues associated with stress, workload
                               demands, or other intangible work factors are more difficult to address
                               than are physical hazards.


Facilities Track Progress in   Perhaps because of these difficulties in tying outcomes to program efforts,
Implementing Their             facility officials found it useful to track the actions taken to implement the
Programs                       core elements of the program. Several of the facilities, for example, had a
                               corporationwide audit, which included a section on ergonomics. These
                               audits assessed items such as whether a team had been established,
                               whether the facility was providing ergonomics training, and whether the
                               facility was conducting analyses of problem jobs. For example, in
                               response to last year’s safety audit, the Navistar facility decided to form an
                               ergonomics committee of high-level management personnel to spread
                               awareness of its ergonomics program and to obtain greater commitment
                               from these managers.

                               Some facilities used other measures to track program implementation. The
                               Texas Instruments facility uses a “productivity matrix” to track progress
                               on various projects or initiatives, including its workstation adjustment
                               campaigns, which have helped identify ergonomic hazards before injuries
                               occur. Both the Texas Instruments and American Express Financial
                               Advisors facilities’ databases, which include employee workstation
                               measurements and preferences, allow them to track the number of
                               employees who have received workstation evaluations and whose
                               workstations have been adjusted. Some facilities are also tracking the
                               number of requests for assistance they receive from employees.


                               These private sector experiences highlight that employers can achieve
Case Study                     positive results through simple, informal, site-specific efforts, with a lower
Experiences Highlight          level of effort to identify and analyze problem jobs than that generally
Employers’ Success in          reflected in the safety and health literature or in OSHA’s draft ergonomics
                               standard. These experiences suggest that OSHA may need to provide
Reducing MSDs                  flexibility to employers to customize their programs under a specified
                               framework for a worksite ergonomics program and give them some

                               43
                                 The work organization factors (sometimes called psychosocial factors) can also include production
                               line speed, workload, the level of control an employee has over his or her job, and degree of job
                               security. A 1995 study by the Communication Workers of America found that consideration of these
                               factors is essential to future progress in reducing MSDs among video display terminal operators.



                               Page 35                                 GAO/HEHS-97-163 Private Sector Ergonomics Programs
                            B-277451




                            discretion in deciding the appropriate level of effort necessary to
                            effectively reduce identified hazards. Federal and state-operated OSHA
                            programs’ current efforts to reduce MSDs in the absence of a standard
                            provide employers this kind of flexibility; however, questions exist about
                            whether current efforts alone are sufficient to address MSDs. Finally, the
                            information problems that complicated these facilities’ efforts to identify
                            their problem jobs, and then to measure their progress in addressing these
                            hazards, suggest that OSHA’s recent efforts to revise injury and illness data
                            collection methods are a step in the right direction.


Flexibility in              All of the facilities in our review implemented the core elements of
Implementation and Lower    effective ergonomics programs. In other words, each of the facility’s
Level of Effort Can         programs included all of the elements highlighted by literature and experts
                            as necessary for an effective program. However, the facilities often
Produce Results             customized the elements to adapt to their own often unique site-specific
                            conditions. We also found that the processes for identifying and
                            developing controls for problem jobs, and often the controls themselves,
                            were simple and informal, generally requiring a lower level of effort than
                            that called for in the OSHA draft standard or described in the literature. Yet,
                            in all cases, the facilities were able to reduce workers’ compensation costs
                            associated with MSDs and the number of days employees were away from
                            work, as well as report improvements in product quality, employee
                            morale, and productivity. This similarity in overall framework but variety
                            in implementation suggests that there may be merit to an approach that
                            requires programs to have these core elements but gives facilities some
                            latitude to customize the elements as they believe appropriate, as well as
                            some discretion to determine the appropriate level of effort necessary to
                            effectively identify and control problem jobs. This approach may also
                            mean that facilities would be able to identify problem jobs—at least
                            initially—on an incidence basis (a report of an MSD or employee
                            discomfort or a request for assistance) and move toward a more proactive
                            identification as the program matures. Although this approach is viewed
                            by some as inconsistent with accepted safety and health practices that
                            emphasize prevention, our case study facilities found it to be a viable
                            approach when starting their programs.


OSHA’s Current Efforts in   In the absence of a standard specifically for MSDs, federal and
Absence of Standard         state-operated OSHA programs have limited authority to take action against
Provide Employers           employers for ergonomic hazards, which has resulted in a variety of
                            strategies and approaches to foster employer awareness and action to
Flexibility


                            Page 36                        GAO/HEHS-97-163 Private Sector Ergonomics Programs
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protect employees from these hazards. These efforts include a number of
new initiatives at the federal and state levels as well as some long-standing
efforts to encourage employers to take action against ergonomic hazards.
These initiatives appear to provide the kind of flexibility that is consistent
with the experiences of our case study employers. Although these
initiatives illustrate the potential value of a flexible approach, many are
small in scope, are resource intensive, are still being developed, or depend
largely on an employer’s willingness to participate, so they may not offer a
complete solution to protecting employees from MSDs, especially in light of
the large numbers of employees that experience MSDs. Federal and
state-operated OSHA programs have tried to provide information, technical
assistance, and consultation in an effort to respond to employers’ interest
in these initiatives.

The flexibility provided by OSHA under the Maine 200 cooperative
compliance program was key to the success of the Sisters of Charity
facility in reducing MSDs. Sisters of Charity was not given targets for
reduction of injuries or hazards, but it was required to implement a
comprehensive safety and health program. To help Sisters of Charity
accomplish this, an OSHA compliance officer was specifically assigned to it
(and to other employers in the health care industry as well) for the
duration of its participation in the program. The compliance officer was
responsible for becoming familiar with the facility to help identify and
evaluate controls, perform on-site monitoring inspections to ensure Sisters
of Charity was implementing the core elements of a safety and health
program, and review quarterly progress reports Sisters of Charity provided
to OSHA. The compliance officer monitored Sisters of Charity’s progress
against the provisions in the Safety and Health Program Management
Guidelines, looking for continuous improvement and “scoring” the facility
on how well it was implementing key elements of the program. Sisters of
Charity graduated from the program in 1996 because it had, in the
judgment of OSHA, made sufficient progress in establishing the elements of
an effective program. Sisters of Charity officials said the value of this
approach was not only the hands-on assistance provided by OSHA, but also
the compliance officer’s familiarity with the facility, which made it
possible for OSHA to appropriately judge the efforts Sisters of Charity was
making. OSHA is currently developing a safety and health program




Page 37                        GAO/HEHS-97-163 Private Sector Ergonomics Programs
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management standard based on the guidelines and on evidence that such
worksite programs can reduce injuries and illnesses.44

OSHA’s settlement agreements for MSDs have also provided some degree of
flexibility, as they require employers to implement core elements of an
ergonomics program but allow employers to carry out these elements
under negotiated timetables with little threat of citation unless the
company fails to comply with the overall agreement.45 OSHA attributes
significant progress made by selected employers in reducing ergonomic
hazards to a great extent to these agreements. In addition, we interviewed
officials from two states with regulations that require employers to
establish worksite safety and health programs or committees who view
these regulations as a way to leverage existing resources to encourage
employers to address ergonomic hazards, especially when MSDs constitute
a significant portion of their injuries and illnesses. Officials said these
programs require employers to take actions to reduce injuries and
illnesses but allow the employers some discretion about what actions they
will take.

North Carolina offers a model of combining a flexible regulatory
approach—as reflected in the CAP program, which has general
requirements for implementing the core elements of an ergonomics
program—with the provision of technical assistance through the state’s
Ergonomics Resources Center. Several employers involved with this effort
said that the flexibility in these agreements and the availability of technical
assistance were very helpful to them, because they were new to
ergonomics and did not know where to begin.

Although these initiatives reflect the value of employer-provided
flexibility, they may not offer a complete solution to protecting employees
from MSDs. For example, while the Sisters of Charity facility demonstrated
significant reductions in workers’ compensation costs for MSDs and in the
number of days employees lost from work, progress was more mixed in
terms of reducing all injuries and illnesses, the average cost per MSD, and




44
  In its draft strategic plan, OSHA reported that effective implementation of safety and health programs
has proven that safety pays in monetary savings as well as in better economic performance, improved
labor/management relations, reduced worker turnover rates, and improved worker morale. We have
previously reported that comprehensive safety and health programs can help employers reduce
injuries, illnesses, and fatalities. See GAO/HRD-92-68, May 19, 1992.
45
 OSHA is currently evaluating the effectiveness of its settlement agreements in improving worker
health and safety.



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the number of days employees were assigned to restricted work activity.46
While these results would suggest that the facility has made some
progress, it is not clear whether the requirements of the Maine 200
program ensure that this would be the case for every employer or that
employees are adequately protected. Additionally, OSHA officials in Maine
said the Maine 200 program required more resources than originally
anticipated and that if they were to do this again, they might be more
selective in the number of employers they targeted.47 Moreover, safety and
health program requirements exist only in some states and often for
selected industries, which limits the number of employers covered. The
North Carolina initiative is small and new and has not yet been fully
evaluated. OSHA’s efforts to expand Cooperative Compliance Programs
similar to Maine 200 to other states continue to evolve, as OSHA deals with
the difficult issues raised by employers and labor advocates alike about
the most effective ways to target employers for inclusion into these
programs, provide employers flexibility to take action, and adequately
protect employees. Additionally, labor representatives have stressed the
need for OSHA to provide (1) the necessary guidance to employers who are
targeted by these programs so they know what actions to take and (2) the
tools to OSHA compliance officers to help them adequately evaluate
employer efforts. In the absence of a standard, these programs rely largely
on an employer’s willingness to take action to reduce ergonomic hazards.

Our case study employers reported that, although they had made
significant use of in-house engineering and other resources to analyze
problem jobs and develop controls, they did, on occasion, call upon
outside resources, including consultants, for information and technical
assistance. These officials said that other employers, especially smaller
ones, may have an even greater need for help from outside resources to
learn how to implement a program or develop controls. This suggests a
role for OSHA’s consultation assistance programs in providing, or
facilitating the dissemination of, information and technical assistance. For
example, 34 states have ergonomics resource personnel among their
consultation program staff, according to a recent OSHA survey, and many
states offer clearinghouses of information on MSDs, provide training, or
have launched technical assistance initiatives specifically for ergonomics.

46
  For example, the nursing home operation actually experienced a slight increase in injuries and
illnesses during the period, but the significant reductions in injuries and illnesses at the medical center
enabled the Sisters of Charity facility as a whole to realize a reduction in workers’ compensation costs
and incidence rates. One evaluation of the Maine 200 program raised questions about its success
because, even though there were often reductions in costs and injuries, it was not possible to
determine with certainty how much improvement was due to specific elements of the Maine 200
program.
47
  Additionally, California state-operated program officials said that they are now more selective about
the use of special orders because the orders are labor intensive to develop and monitor.


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                          B-277451




                          Federal and state-operated OSHA programs also provide grants to
                          employers—for example, to smaller employers to provide for ergonomic
                          training, or, as in Oregon, to employers or employer groups to develop and
                          implement solutions to workplace ergonomic problems that cannot be
                          solved with available technology. The Washington state-operated program
                          is conducting research to help employers address MSDs, and it has formed
                          a task force to develop a strategy to reduce MSDs in high-risk industries.
                          OSHA has also undertaken projects to help employers understand the
                          financial benefits of taking action and to share practical experiences about
                          how to implement an ergonomics program.48


Lack of Adequate          At the facilities we visited, the impetus for developing an ergonomics
Information Complicates   program was often an initial concern with excessive workers’
Program Operations and    compensation costs. At these facilities, this concern led to an examination
                          of workers’ compensation and other data that ultimately identified MSDs as
Measurement               a cause of a major proportion of their total workers’ compensation costs.
                          Later, to facilitate the tracking of their programs’ progress, these
                          companies, either on their own or through their workers’ compensation
                          insurers or third-party administrators, set up systems for tracking
                          MSD-related injuries and associated costs.


                          However, other companies, even if they have high workers’ compensation
                          costs, may not have access to the information needed to determine
                          whether they have a problem with MSDs and, if so, how to address the
                          problem. Further, although employers are currently required to record
                          information on workplace injuries and illnesses on the OSHA 200 log, the
                          case study facilities have found that the log does not facilitate the
                          collection of accurate data on MSDs. In 1996, OSHA proposed changes to
                          simplify how all injuries and illnesses could be recorded on the OSHA 200
                          log.49 As a part of this proposal, OSHA specified criteria for recording MSDs
                          that would include a diagnosis by a health care provider that an injury or
                          illness is an MSD and an “objective” finding, such as inflammation, or a
                          report of two or more applications of hot or cold therapy. These criteria
                          would be applied equally to all cases involving any part of the body,
                          including backs. This proposal would respond to concerns raised by the
                          case study employers that the “repeated trauma” illness category in the
                          OSHA 200 log does not adequately capture all MSDs.


                          48
                           For example, in Jan. 1997, OSHA and NIOSH jointly sponsored a conference entitled “Ergonomics:
                          Effective Programs and Practices.” OSHA officials have announced they plan to hold additional
                          conferences throughout the country.
                          49
                            This proposal was explained in detail in the Feb. 2, 1996, Federal Register and is currently under
                          review at the Department of Labor and the Office of Management and Budget.



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                     B-277451




                     Currently, billions of dollars are spent by private sector employers on
Conclusions          workers’ compensation claims associated with MSDs, and hundreds of
                     thousands of workers each year suffer from MSDs. Our work has
                     demonstrated that employers can reduce these costs and injuries and
                     thereby improve employee health and morale, as well as productivity and
                     product quality. More importantly, we found that these efforts do not
                     necessarily have to involve costly or complicated processes or controls,
                     because employers were able to achieve results through a variety of
                     simple, flexible approaches. Our findings are based on a small number of
                     cases and are not generalizable to all workplaces. However, the qualitative
                     information provides important insights into employers’ efforts to protect
                     their workers from ergonomic hazards. Additionally, experts from the
                     business, labor, and academic communities reviewed the results of our
                     case studies and said our findings on employer efforts to reduce MSDs were
                     consistent with their experiences.

                     Our work also found that these facilities’ programs included all of the core
                     elements highlighted in the literature and by experts as key to an effective
                     program—management commitment, employee involvement,
                     identification of problem jobs, analyzing and developing controls for
                     problem jobs, training and education, and medical management—with the
                     elements customized to account for local conditions. Uncertainties
                     continue to exist about particular aspects of MSDs that may complicate
                     regulatory action by OSHA, and our analysis does not allow us to draw any
                     conclusions about whether a standard for MSDs is merited. However, any
                     approach OSHA pursues to protect workers from ergonomic hazards that
                     sets a well-defined framework for a worksite ergonomics program that
                     includes these elements while allowing employers flexibility in
                     implementation would be consistent with the experiences of these case
                     study employers.


                     We obtained comments on a draft of this report from the Department of
Agency Comments      Labor’s Acting Assistant Secretary for Occupational Safety and Health.
and Our Evaluation   OSHA also provided technical changes and corrections to this report, which
                     we incorporated as appropriate.

                     In his comments, the Acting Assistant Secretary said that our report is a
                     valuable contribution to the extensive literature on the benefits of
                     ergonomic programs and that it reinforces conclusions found elsewhere in
                     the literature that ergonomic interventions in the workplace significantly
                     reduce work-related injuries and illnesses. He described the reduction in



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B-277451




workers’ compensation costs for MSDs for these facilities as impressive and
noted that these facilities had implemented substantially the same core
elements as those OSHA has recognized as fundamental to ergonomics
programs.

Although the Acting Assistant Secretary described the report as consistent
with OSHA’s ergonomics experience, he pointed out that our study cannot
be used to draw any conclusions about the relative advantages of an
incidence-based approach (identifying problem jobs on the basis of a
report of injury or discomfort or an employee request for assistance)
versus more proactive approaches. Although the facilities we studied used
an incidence-based approach to identify problem jobs, the Acting Assistant
Secretary expressed the view that incidence-based approaches are
unlikely to work as effectively where there is a small number of workers in
a job, as is typical of many small and medium-sized firms. We agree that
our study does not allow us to compare the relative advantages of different
approaches for identifying problem jobs. Rather, we found that these
facilities believed an incidence-based approach was a viable way to start
identifying where their problems lay. We also reported that these facilities
are now moving to more proactive approaches to identify potential
problem jobs, before complaints or discomfort occur. The comments of
Labor’s Acting Assistant Secretary appear in their entirety in appendix
VIII.

We are providing copies of this report to the Secretary of Labor; the Acting
Assistant Secretary for Occupational Safety and Health; state-operated
program representatives; and others, upon request. If you have any
questions on this report, please contact me on (202) 512-7014. Staff who
contributed to this report are listed in appendix IX.




Carlotta C. Joyner
Director, Education and
  Employment Issues




Page 42                       GAO/HEHS-97-163 Private Sector Ergonomics Programs
Page 43   GAO/HEHS-97-163 Private Sector Ergonomics Programs
Contents



Letter                                                                                              1


Appendix I                                                                                         48
                        Selection Process Used for Case Study Facilities                           50
Objectives, Scope,      Review of Case Study Results                                               51
and Methodology         Issues to Consider Regarding Data for Case Study Employers                 53

Appendix II                                                                                        56

Profiles of Selected
Problem Jobs at the
Case Study Facilities
Appendix III                                                                                       59
                        Background                                                                 59
The Ergonomics          Initiating the Ergonomics Program at AEFA                                  60
Program at AEFA         Structure and Core Elements of the Program at AEFA                         61
                        Results and Issues Related to Program Performance                          68
Headquarters,
Minneapolis,
Minnesota
Appendix IV                                                                                        72
                        Background                                                                 72
The Ergonomics          Initiating the Ergonomics Program at Tower City                            72
Program at AMP,         Structure and Core Elements of the Program at Tower City                   73
                        Results and Issues Related to Program Performance                          82
Electronic Connectors
Manufacturing
Facility, Tower City,
Pennsylvania




                        Page 44                     GAO/HEHS-97-163 Private Sector Ergonomics Programs
                         Contents




Appendix V                                                                                            86
                         Background                                                                   86
The Ergonomics           Initiating the Ergonomics Program at Springfield                             87
Program at Navistar,     Structure and Core Elements of the Program at Springfield                    88
                         Results and Issues Related to Program Performance                            97
Springfield Assembly
Facility, Springfield,
Ohio
Appendix VI                                                                                          101
                         Background                                                                  101
The Ergonomics           Initiating the Ergonomics Program at SOCHS                                  102
Program at SOCHS,        Structure and Core Elements of the Program at SOCHS                         102
                         Results and Issues Related to Program Performance                           111
Lewiston, Maine
Appendix VII                                                                                         116
                         Background                                                                  116
The Ergonomics           Initiating the Ergonomics Program at Lewisville                             117
Program at TI,           Structure and Core Elements of the Program at Lewisville                    118
                         Results and Issues Related to Program Performance                           131
Defense Systems and
Electronics Group
Headquarters,
Lewisville, Texas
Appendix VIII                                                                                        135

Comments From the
Department of Labor
Appendix IX                                                                                          137

GAO Contacts and
Acknowledgments
Tables                   Table 1: Employers and Facilities Selected for Case Studies                   3
                         Table I.1: Years Facilities’ Programs Were Fully Implemented and             54
                           Years of Data Used
                         Table I.2: Categories of Injuries and Illnesses Tracked as MSDs at           55
                           Case Study Facilities




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          Contents




Figures   Figure 1: Percentage Reduction in Workers’ Compensation Costs               27
            for MSDs at the Case Study Facilities
          Figure 2: Change in Lost and Restricted Workdays for Case Study             29
            Facilities
          Figure 3: Average Cost per MSD Workers’ Compensation Claim                  30
            for Case Study Facilities
          Figure 4: Reduction in Injury and Illness Incidence Rates at Case           31
            Study Facilities
          Figure III.1: Workers’ Compensation Costs for MSDs at AEFA,                 69
            1992-96
          Figure IV.1: Workers’ Compensation Costs for MSDs at the AMP                83
            Facility, 1993-96
          Figure V.1: Workers’ Compensation Costs for MSDs at the                     98
            Navistar Facility, 1993-96
          Figure VI.1: Workers’ Compensation Costs for MSDs at SOCHS’                113
            Medical Center and Nursing Home, 1994-96
          Figure VII.1: Workers’ Compensation Costs for MSDs at the TI               132
            Facility, 1991-96




          Abbreviations

          AEFA       American Express Financial Advisors, Inc.
          AMP        AMP Incorporated
          BLS        Bureau of Labor Statistics
          CAP        Cooperative Assessment Program
          CAT        corrective action team
          CNA        certified nursing assistant
          CSO        Client Service Organization
          MSD        musculoskeletal disorder
          NIOSH      National Institute for Occupational Safety and Health
          OSHA       Occupational Safety and Health Administration
          QIT        Quality Improvement Team
          SAFE       Safety Assessment of Facility Excellence
          SOCHS      Sisters of Charity Health System
          TI         Texas Instruments
          UAW        United Auto Workers
          VAM        value-added manufacturing


          Page 46                      GAO/HEHS-97-163 Private Sector Ergonomics Programs
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Appendix I

Objectives, Scope, and Methodology


                 We were asked to (1) identify the core elements of effective ergonomics
                 programs and how these elements are operationalized at the local level,
                 (2) discuss whether these programs have proven beneficial to the
                 employers and employees that have implemented them, and (3) highlight
                 the lessons to be learned from these experiences by other employers and
                 by OSHA. We conducted our work in accordance with generally accepted
                 government auditing standards between June 1996 and June 1997.

                 To identify the core elements of effective ergonomics programs, we

             •   reviewed the pertinent literature, including key reports, studies, and
                 guidelines issued by the Occupational Safety and Health Administration
                 (OSHA), the National Institute for Occupational Safety and Health, the
                 American National Standards Institute, and others over the last decade on
                 ergonomics and implementation of safety and health programs; the OSHA
                 1995 draft ergonomics standard; the American National Standards Institute
                 Voluntary Draft Standard on musculoskeletal disorders (MSD); public
                 comments received in response to OSHA’s 1992 Advance Notice of Public
                 Rulemaking for an ergonomics standard; OSHA’s settlement agreements
                 regarding MSDs; and other OSHA efforts leading up the draft standard and
             •   interviewed and obtained data from experts in ergonomics and related
                 fields and representatives from the employer and labor community with
                 experience in implementing such programs.

                 To identify how these elements were operationalized at the local level and
                 determine whether these programs have proven beneficial, we

             •   interviewed and obtained data from experts known for their research on
                 the costs and benefits of these programs to obtain information on how
                 employers can measure effectiveness of programs, interviewed Bureau of
                 Labor Statistics (BLS) officials about their efforts to track injuries and costs
                 of those injuries, and obtained information on workers’ compensation
                 costs;
             •   selected facilities of five employers that experts believed to have fully
                 implemented programs and that had achieved reductions in workers’
                 compensation costs resulting from MSDs and conducted case studies
                 between January and February 1997 to obtain information about their
                 experiences implementing these programs;
             •   administered a results survey to the selected facilities to collect data used
                 by these facilities to measure their success, such as data used to track
                 program progress and information pertinent to the evaluation of these




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    Objectives, Scope, and Methodology




    data, such as workforce size (we did not independently validate these
    data); and,
•   following a detailed protocol that obtained information on how core
    elements were implemented and that identified results achieved,
    difficulties in implementing the programs, barriers faced, lessons learned
    by the employers from their experiences, and employers’ views of OSHA
    and others’ roles to reduce MSDs, visited each of these facilities and
    interviewed facility management, other officials responsible for or
    involved with the ergonomics program, and staff-level employees;
    obtained additional results information in order to corroborate
    information gained during interviews, as well as documentation of the
    program, training provided, and information provided to employees about
    the program; and interviewed pertinent officials from the corporate
    headquarters about the selected facilities’ experiences compared with
    those of the employers’ other facilities.

    To identify the lessons learned from employer experiences and the
    implications for OSHA strategies to reduce MSDs, we

•   obtained case study employers’ views on OSHA’s role in reducing MSDs on
    the basis of employers’ experiences;
•   interviewed officials in selected states that operated their own safety and
    health programs—California, Maryland, Michigan, Minnesota, North
    Carolina, Oregon, Washington, and Virginia—and obtained information
    about their efforts to encourage employers to reduce MSDs; reviewed the
    benefits and disadvantages of these approaches in light of our case study
    findings; and conducted on-site interviews with officials from North
    Carolina and California to discuss the merits and disadvantages of their
    particular efforts—an ergonomics resources center in North Carolina and
    a standard for repetitive trauma in California—to reduce MSDs;
•   interviewed various OSHA officials, officials from Labor’s Solicitor’s office,
    and other Labor officials to obtain information on Labor’s efforts to
    encourage employers to reduce MSDs; interviewed OSHA officials in Maine
    to obtain information on the merits and disadvantages of the Maine 200
    program; and reviewed the status of Labor’s past efforts to reduce MSDs,
    including challenges by employers of Labor’s use of the general duty
    clause for MSDs and of other OSHA programs; and
•   reviewed results with several panels of business and labor representatives
    and noted experts in the field of ergonomics.




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                      Appendix I
                      Objectives, Scope, and Methodology




                      Through interviews, a review of the literature, and requesting nominations
Selection Process     using trade association bulletin boards, we identified 132 employers that
Used for Case Study   experts believed had made gains in reducing workers’ compensation costs
Facilities            associated with MSDs. We used a multitiered screening process to select
                      the five case study facilities.

                      We had decided that three of our five case studies would be in the
                      manufacturing industry since the manufacturing industry has had the
                      longest experience with MSDs. BLS 1994 data reported this industry had the
                      highest number of occupational injuries and illnesses involving days away
                      from work for repetitive motion, and OSHA had targeted sectors of this
                      industry in the early 1990s for the presence of ergonomic hazards. We
                      decided that the other two case studies would be in industries where
                      concerns about emerging ergonomic hazards were increasing. BLS 1994
                      data showed that other industries (such as services, retail trade, and
                      communications) known for office environments and the use of
                      computers were reporting high rates of illnesses due to repeated trauma,
                      and interviews with experts and a review of the current articles in the
                      press revealed increasing concerns about hazards in the office
                      environment. There was also concern about the hazards in the health care
                      industry; in fact, in 1996, OSHA instituted an initiative to provide training to
                      nursing homes to reduce injuries. As a result, we decided the other two
                      case studies would include an employer whose employees worked largely
                      in an office or computer environment and an employer in the health care
                      industry.

                      We categorized the 132 nominations by manufacturing and other
                      industries. Focusing on the nominations in the manufacturing industry, we
                      narrowed the selection to 25 employers on the basis of the data available
                      at that time about the employer’s program; general knowledge of the
                      employer’s safety and health practices; and other factors, such as whether
                      these employers had already been subjects of other case studies. We
                      discussed each of these 25 employers and then, through a multivoting
                      approach, narrowed the selection to 11 employers that we would contact
                      for further information. We followed the same procedure for the
                      nominated employers in the other industries and narrowed the selection to
                      11 employers that we would call for additional information.

                      We then attempted to contact the headquarters office of each of these
                      employers and, using a screening protocol, obtained basic information
                      about program implementation and results. We asked for additional
                      information to allow us to make a final selection, including whether these



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                       Appendix I
                       Objectives, Scope, and Methodology




                       employers used data to track their programs’ success, whether they
                       believed the program was fully implemented, and any results data that had
                       already been collected.

                       Given the results of the screening protocols and information subsequently
                       provided by these employers, including their willingness to participate, we
                       selected five employers for our case studies: American Express Financial
                       Advisors (AEFA), AMP Incorporated (AMP), Navistar International
                       Transportation Corp. (Navistar), Sisters of Charity Health System (SOCHS),
                       and Texas Instruments (TI). We asked each of these employers to
                       nominate a facility that it felt had the most fully implemented program.


                       Our work is based predominantly on case studies of five employers that
Review of Case Study   believe their programs are effective at reducing workers’ compensation
Results                costs for MSDs. It was not possible for us to discern whether the
                       characteristics of effective programs are unique to these programs. The
                       information we present is not generalizable to the employer community as
                       a whole.

                       We reviewed the findings of our case studies with representatives from the
                       employer, labor union, and academic communities who were
                       knowledgeable about ergonomics and worksite ergonomics programs to
                       gauge the plausibility of the information we collected. The first panel, held
                       in San Jose, California, on March 18, 1997, was cosponsored by the Silicon
                       Valley Ergonomics Institute, which is part of San Jose State University.
                       The business panel members were predominantly high-tech computer
                       manufacturers who had experience with or were interested in
                       implementing ergonomics programs. Medical practitioners and
                       researchers also sat on this panel. The second panel was held on April 8,
                       1997, in Washington, D.C., with members of the Center for Office
                       Technology, which is a trade association representing employers in the
                       manufacturing, communications, and other industries. The third panel was
                       held on April 15, 1997, in Alexandria, Virginia, with selected members of
                       the National Coalition on Ergonomics. We also reviewed our findings with
                       a labor union panel on May 15, 1997, that consisted of employee
                       representatives from the manufacturing, construction, and service
                       industries, among others. These panelists said our findings regarding the
                       level of effort being made by employers to identify and address MSDs, the
                       results of the efforts, and the issues regarding the difficulty of measuring
                       program effectiveness were generally consistent with their experiences
                       and knowledge about employers’ current efforts to implement worksite



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Appendix I
Objectives, Scope, and Methodology




ergonomics programs. We also provided the draft report to a selection of
representatives from business, labor, and academia for their review and
comment and incorporated their comments as appropriate. The following
employers, unions, and associations were represented in these panels or
reviewed our draft report.

AFL-CIO
American Federation of Government Employees
American Federation of Musicians
Apple Computer, Inc.
Association of Flight Attendants
AT&T
Auburn Engineers
Bank of America
Bell Atlantic
Center for Office Technology
Center to Protect Workers’ Rights
CIGNA Corporation
Communication Workers of America
Environmental and Occupational Risk Management
Peter Estacio, Ergonomics Consultant
Ford Motor Company
General Motors Corporation
Hewlett Packard
IBM
Keller and Heckman
Massachusetts Coalition for Safety and Health
MCI
NCR Corporation
Newspaper Association of America
Palo Alto Medical Center
San Jose State University
Semiconductor Industry Association
Service Employees International Union
Silicon Graphics
Silicon Valley Ergonomics Institute
Sports and Occupational Medicine Association
3Com Corporation
3M
Transport Workers Union
Travelers Property Casualty
Union of Needle Trades, Industrial, and Textile Employees



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                       Appendix I
                       Objectives, Scope, and Methodology




                       United Auto Workers
                       United Food and Commercial Workers
                       USAA


                       Significant differences in the data provided by the case study facilities
Issues to Consider     make comparison among the facilities inappropriate. For example, data
Regarding Data for     presented for each of the facilities vary depending upon when the facility
Case Study Employers   believes the program was fully implemented (according to its own
                       definition of what constitutes “fully implemented”) and the availability of
                       data. We made every effort to present cost and injury- and illness-related
                       data starting with the year prior to the program’s full implementation
                       through 1996 in order to show changes at the facility during the program’s
                       operation. We worked with each of these facilities to agree upon a date
                       that could be appropriately used as the year before the program’s full
                       implementation and obtain the appropriate data. However, in some cases,
                       appropriate data were not available, and we were unable to present data
                       prior to the program’s full implementation. Table I.1 shows the years the
                       programs were fully implemented at the facilities and the resulting years
                       used for the data.




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                                        Appendix I
                                        Objectives, Scope, and Methodology




Table I.1: Years Facilities’ Programs
Were Fully Implemented and Years of                                                  Year program fully
Data Used                               Case study facility                               implemented                 Years of data used
                                        AEFA                                                         1993                           1992-96a
                                        AMP                                                          1993                           1993-96b
                                        Navistar                                                     1994                           1993-96
                                        SOCHS                                                        1994                           1994-96c
                                        TI                                                           1992                           1991-96
                                        a
                                          The “OSHA 200 log” is the form used by most employers to record work-related injuries and
                                        illnesses that require more than first aid. AEFA is not required by law to maintain the OSHA 200
                                        log but does so because the facility is included in the employer universe for BLS’ Occupational
                                        Injury and Illness Survey, which is based on the OSHA 200 log data. Officials said no OSHA 200
                                        log data are available prior to 1994, nor are any data available on work hours, which are
                                        necessary to compute specific injury and illness rates. As a result, OSHA 200 log data are not
                                        included in this report for AEFA. Also, workers’ compensation data are categorized by policy year
                                        rather than calendar year. For example, policy year 1991 is from Sept. 30, 1991, through Sept. 29,
                                        1992. For purposes of this report, we refer to policy year 1991 as “1992,” policy year 1992 as
                                        “1993,” and so on.
                                        b
                                         AMP workers’ compensation data for 1992 (the year of full implementation) are not comparable
                                        with data for later years. As a result, we did not use 1992 workers’ compensation data, nor did we
                                        use available injury- and illness-related data from the OSHA 200 log for that year.
                                        c
                                          Workers’ compensation data for SOCHS are not available for 1993 because it was insured
                                        through a carrier for the majority of 1993 and only has information on premiums paid. As a result,
                                        figures based on workers’ compensation data use 1994 as the base year. However, injury- and
                                        illness-related data from the OSHA 200 log were available for 1993, the year before the program’s
                                        full implementation. Because there were so few years’ data available for workers’ compensation
                                        costs, we decided to use OSHA 200 log data starting in 1993. SOCHS officials said that, in some
                                        cases, early years of data (such as for work hours and numbers of claims) have been estimated.



                                        Case study facility data also cannot be compared because each facility
                                        tracks different categories of injuries, illnesses, or both as MSDs at their
                                        facilities. Table I.2 shows the categories used by the facilities.




                                        Page 54                                 GAO/HEHS-97-163 Private Sector Ergonomics Programs
                                        Appendix I
                                        Objectives, Scope, and Methodology




Table I.2: Categories of Injuries and
Illnesses Tracked as MSDs at Case       Case study facility                  Injuries and illnesses tracked
Study Facilities                        AEFA                                 Computer, mouse, and other repetitive motion injuriesa
                                        AMP                                  Sprains and strains in which a cause of injury is lifting,
                                                                             repetitive motion, pushing, or pulling
                                        Navistar                             Injuries due to repetitive trauma, carpal tunnel syndrome,
                                                                             thoracic outlet syndrome, tendinitis, epicondylitis, rotator
                                                                             cuff injuries, torn meniscus, and acute strains to the back
                                        SOCHS                                Cumulative trauma injuries (for example, carpal tunnel
                                                                             syndrome and overuse syndrome), tendinitis,
                                                                             epicondylitis, and back injuriesb
                                        TI                                   Injuries from repetitive motion and body stress (from
                                                                             performing lifting tasks)
                                        a
                                         Other repetitive motion injuries do not include stress, strain, or lifting injuries because the
                                        program is just starting to address these types of injuries.
                                        b
                                         Officials said not all back injuries that occur are considered MSDs for the purposes of the
                                        ergonomics program. For example, in many cases, injuries have been caused by trips and falls
                                        on icy parking lots. As a result, including all back injuries for the purposes of this report may be
                                        overestimating the number that are due to ergonomic hazards.




                                        Page 55                                    GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix II

Profiles of Selected Problem Jobs at the
Case Study Facilities




               Page 56      GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix II
Profiles of Selected Problem Jobs at the
Case Study Facilities




Page 57                             GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix II
Profiles of Selected Problem Jobs at the
Case Study Facilities




Page 58                             GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix III

The Ergonomics Program at AEFA
Headquarters, Minneapolis, Minnesota

               Formerly Investors Diversified Services, Inc., American Express Financial
Background     Advisors, Inc., was acquired by American Express in 1984 and provides
               financial planning services. AEFA is headquartered in Minneapolis,
               Minnesota, and employs about 8,000 nonunion employees in about 250
               locations throughout the country.50 Most of the employees work at the
               headquarters office, and the majority of AEFA employees work in an office
               environment using computers, so they face similar types of hazards. To
               date, the ergonomics program has focused on these employees but is now
               beginning to study more closely employees who face lifting and other
               manual material handling hazards.

               The culture of AEFA has influenced program implementation. AEFA’s efforts
               began many years ago as a commitment to improving employee comfort
               and satisfaction. AEFA officials told us they believed a significant portion of
               their employees’ injuries, and resulting workers’ compensation costs, was
               MSD-related, caused by repetitive motion, stress, strain, and lifting. AEFA
               has made a significant investment in training employees in the office
               environment to increase their awareness of hazards and the need for early
               reporting. Recent managerial and organizational changes, such as changes
               in program staff and the results of decisions by corporate management,
               pose new challenges for the continuity of the program.

               Program implementation also needs to be considered in light of the local
               facility characteristics. AEFA as an organization has experienced significant
               growth in staffing levels since 1988. Additionally, many of AEFA’s
               employees work in the Client Service Organization (CSO), which is one of
               the most computer- and phone-intensive units in AEFA. Employees in this
               unit are responsible for responding to client questions or problems,
               accessing information from their computers, and recording information in
               manual logs. Some employees spend 3 to 4 hours a day answering about 30
               to 40 telephone calls, while others average about 6-1/2 to 7 hours per day
               on the telephone answering 80 to 100 calls. Issues related to workload and
               increased staffing levels present special challenges to the program;
               officials told us these issues are more difficult to address than are physical
               workplace hazards.




               50
                There are also about 8,000 to 10,000 independent contractors (called financial advisers) who sell
               AEFA’s services. These individuals are not considered AEFA employees.



               Page 59                                  GAO/HEHS-97-163 Private Sector Ergonomics Programs
                     Appendix III
                     The Ergonomics Program at AEFA
                     Headquarters, Minneapolis, Minnesota




                     The current ergonomics program at AEFA was fully implemented in 1993,
Initiating the       when a full-time ergonomist and other ergonomics staff were hired,
Ergonomics Program   training was provided to all employees, and an effort was made to infuse
at AEFA              ergonomic principles into equipment purchase and design. The current
                     program has evolved from a decade of effort originally based on the goal
                     of making AEFA “the best place to work” by removing employee discomfort
                     and reducing workers’ compensation costs associated with MSDs.

                     AEFA   started to address ergonomics in 1986, when it established an
                     ergonomics task force and began conducting a limited number of
                     workstation evaluations. In 1990, it hired a consultant to provide
                     ergonomics awareness training to selected departments that faced
                     ergonomic hazards. AEFA’s safety department began to receive employee
                     complaints about physical discomfort and requests to evaluate their
                     workstations to improve the layout, which officials believed was at least
                     partly the result of this training. AEFA staff tried to accommodate these
                     requests but were unable to keep up with the demand. Additionally, in
                     1992, workers’ compensation costs for MSDs increased significantly. Then,
                     after the 1993 budget had been approved, the director of support services
                     decided to establish an ergonomics function in his department. Assuring
                     top management that this action would not affect budget or personnel
                     ceilings, he reallocated a portion of his furniture budget to support a
                     full-time ergonomist to be responsible for the program. This ergonomist
                     was hired in 1993 and took the lead in implementing the program.51

                     A major staff reorganization also provided the opportunity to develop an
                     ergonomics function. This reorganization required a physical relocation to
                     new space and new furniture. In determining what type of furniture to
                     obtain, the purchasing, real estate, and facilities departments believed
                     that, if AEFA could buy furniture that could be easily adjusted for different
                     employees, AEFA could reduce the costs associated with retrofitting
                     workstations every time employees moved. Because AEFA employees move
                     offices or work locations quite frequently (referred to as the “churn” rate),
                     costs associated with these moves can be significant. This adjustability
                     would also make the furniture “ergonomic”; that is, it could be
                     appropriately adjusted for each employee and provide additional savings
                     from reduced discomfort and reported injuries.




                     51
                       This employee was selected to be the ergonomist for American Express; a new ergonomist was hired
                     for AEFA.



                     Page 60                                GAO/HEHS-97-163 Private Sector Ergonomics Programs
                        Appendix III
                        The Ergonomics Program at AEFA
                        Headquarters, Minneapolis, Minnesota




                        AEFA’s ergonomics program is led by the ergonomics staff (the ergonomist,
Structure and Core      the ergonomics specialist, and a half-time administrative assistant) and is
Elements of the         currently located in the support services department. Various other
Program at AEFA         departments work with the ergonomics staff (such as the real estate,
                        purchasing, facilities, and risk management departments) to design
                        equipment standards, purchase equipment, adjust workstations, and track
                        workers’ compensation claims and costs.


Management Commitment   Management commitment to the ergonomics program at AEFA is
                        demonstrated in a number of ways. AEFA has no formal written program
                        laying out the elements of its ergonomics program. AEFA officials told us a
                        written program is not as key to daily program operations as is the
                        information disseminated during the training and discussed in the
                        employee guidelines, which are provided to each employee (see the
                        training and education section below).

                        Primary among the ways AEFA has demonstrated management
                        commitment has been the assignment of staff—the ergonomist, the
                        ergonomics specialist, and the administrative assistant—to be responsible
                        for the program. The ergonomics staff identifies problem jobs, conducts
                        workstation evaluations, develops controls, provides training to
                        employees, and tracks information about what training and services
                        employees have been provided. Various employees we interviewed said
                        they knew whom to call when they had a question or complaint; the
                        response was quick; and, in most cases, necessary changes were made in a
                        reasonable period of time.

                        AEFA  has also integrated ergonomic principles into the purchase and
                        design of equipment. For example, AEFA assembled a team of employees
                        (for example, the ergonomist, officials from the real estate department,
                        and representatives from various on-line jobs) to select chairs to offer to
                        all employees. This team reviewed available information and selected
                        several potential chairs, which employees then tested and rated. On the
                        basis of employee feedback and other criteria (such as delivery time and
                        warranty), the team selected for purchase the two highest rated chairs. In
                        so doing, AEFA reduced purchasing costs, by buying in large quantities, as
                        well as increased employee comfort. In much the same manner, a team
                        was assembled to design and select new adjustable furniture for private
                        offices. The team, which included the ergonomist, developed
                        specifications for the furniture, then the purchasing and real estate
                        departments worked with a vendor to develop furniture that met these



                        Page 61                           GAO/HEHS-97-163 Private Sector Ergonomics Programs
                       Appendix III
                       The Ergonomics Program at AEFA
                       Headquarters, Minneapolis, Minnesota




                       specifications. In the end, AEFA was able to buy this adjustable furniture
                       for about the same price as other furniture, while it also increased
                       comfort, reduced future injuries, and now expects to save additional
                       resources from not having to retrofit furniture every time employees
                       relocate.

                       AEFA  also has invested significant resources to train employees. Office
                       ergonomics training is strongly encouraged, and employees generally are
                       not able to have their workstations adjusted by the facilities department
                       without first attending training. Additionally, several of the line managers
                       we spoke with said they encourage their employees to go to ergonomics
                       training if they believe any productivity or quality problems may be due to
                       ergonomic hazards. Moreover, many of the employees we spoke with told
                       us they feel their managers take training seriously and encourage them to
                       attend training and obtain the necessary ergonomic equipment to improve
                       comfort. This training is offered every week for 1-1/2 hours—more time
                       than is devoted to any other subject of training, according to AEFA officials.
                       AEFA officials reported that about 70 percent of the headquarters staff have
                       received training since 1993.


Employee Involvement   AEFA  does not use employee committees to identify problem jobs or
                       develop controls. Instead, AEFA has established procedures that enable
                       employees to directly access services. For example, at AEFA, employees are
                       encouraged to attend the weekly ergonomics training, which provides
                       employees information about office ergonomics and how to maintain
                       comfort and health while working on computers. Additionally, during
                       training, employees are measured for appropriate workstation setup (for
                       example, chair height when sitting) and asked to complete an anonymous
                       discomfort survey so that the ergonomics staff can obtain information on
                       the extent to which employees are experiencing discomfort on their
                       current jobs, and on what body parts they are experiencing that
                       discomfort. This survey has also been provided to a random sample of
                       employees annually since 1993. The results of this survey are used to track
                       program performance and, in some cases, identify problem jobs.
                       Additionally, at the end of each training session, employees are asked to
                       provide feedback on the quality of the training received and whether they
                       anticipate making changes to their daily work as a result of the training.

                       Employees also have direct access to ergonomic services through a
                       process that allows them to order computer accessories (such as foot
                       rests, wrist rests, document holders, and monitor risers) from a standard



                       Page 62                           GAO/HEHS-97-163 Private Sector Ergonomics Programs
                            Appendix III
                            The Ergonomics Program at AEFA
                            Headquarters, Minneapolis, Minnesota




                            listing. Costs for these accessories are not charged back to the employees’
                            home work area; instead they are paid for by the real estate department.
                            Employee requests also trigger workstation evaluations, and, during these
                            evaluations, employees also are asked for their input about controls they
                            believe would be appropriate. Employees we interviewed acknowledged
                            their responsibility to look for ergonomic hazards and apply ergonomic
                            principles to their work habits.


Identification of Problem   AEFA  identified problem jobs primarily on an incidence basis. In other
Jobs                        words, most of AEFA’s efforts result from a report of injury or discomfort
                            or an employee request for assistance based on other reasons.52 AEFA
                            officials said reports of discomfort and employee requests account for the
                            majority of workstation evaluations performed. On a more proactive basis,
                            AEFA strongly encourages any employee who is relocating to attend
                            training in order to be measured so the facilities department can set up the
                            employee’s new workstation appropriately. The ergonomics specialist also
                            regularly walks the floor to look for potential problems. Moreover,
                            officials told us that AEFA builds in what it learns to furniture and
                            equipment design.

                            At AEFA, a simple system has been established to ensure that a problem job
                            is identified when an injury is reported. When an employee reports an
                            injury to the risk management department, the department fills out a “First
                            Report of Injury” form.53 If the risk management department determines
                            the injury was due to ergonomic hazards, it forwards the form to the
                            ergonomics staff. After receiving the form, the ergonomics staff contact
                            the employee (after the employee has returned to work, if appropriate) to
                            schedule a workstation evaluation.

                            There is also an informal system to identify problem jobs when no injury
                            has occurred but employees are feeling discomfort or want an evaluation.
                            Employees can request a workstation evaluation through a phone call or
                            an E-mail message to the ergonomics specialist, or by scheduling the
                            evaluation on the ergonomics specialist’s electronic calendar. In some
                            instances, AEFA has also used the results of the discomfort surveys to
                            identify problem jobs.



                            52
                             For example, a supervisor may suggest that a new employee request a workstation evaluation to
                            address productivity or quality problems.
                            53
                              This form lists six categories of nature of injury: repetitive motion; slips, trips, and falls; cuts; stress;
                            strain; and lifting. Back injuries are classified according to their cause.



                            Page 63                                      GAO/HEHS-97-163 Private Sector Ergonomics Programs
                               Appendix III
                               The Ergonomics Program at AEFA
                               Headquarters, Minneapolis, Minnesota




                               The ergonomics staff respond to every request for an evaluation (whether
                               due to an injury, report of discomfort, or other request for assistance)
                               within a few days, typically on a first-come, first-served basis. Several
                               employees we spoke with said the ergonomics staff usually perform
                               evaluations within 48 hours of the request.


Analyzing Problem Jobs         AEFA officials emphasized that, in most cases, they do not do job analysis
and Developing Controls        but instead perform workstation evaluation, and the process used is
                               simple and informal. The process used to develop controls is also typically
                               informal, relying on in-house resources, such as the employees doing the
                               work or staff in the facilities department. AEFA has implemented a mix of
                               controls, focusing on those that increase employee comfort while using
                               computers. Appendix II profiles some of the controls AEFA has
                               implemented.

Process Used to Analyze Jobs   At AEFA, workstation evaluations are typically performed rather than job
                               analysis. AEFA officials said the reason for this is that they focus primarily
                               on identifying what changes need to be made to the physical
                               characteristics of a workstation to make the employee more comfortable
                               performing the tasks. In so doing, certain risk factors (such as awkward
                               postures) may be eliminated, but others (such as repetition) may remain.
                               A job analysis would assess whether the actual job tasks should be
                               changed to reduce hazards associated with that particular job.

                               The ergonomics specialist conducts about 10 workstation evaluations a
                               week during two set periods (at other times, if neither of these is
                               convenient for the employee). During these evaluations, which take about
                               30 minutes, the ergonomics specialist interviews the employee, watches
                               him or her perform the job, and determines whether he or she is
                               performing any activities outside of work that may be contributing to the
                               discomfort or injury. When the evaluation is triggered by an injury, the
                               ergonomics specialist adheres to a questionnaire that collects information
                               about the job (such as whether the workstation is shared, what types of
                               tasks are performed, and how often tasks are performed) as well as about
                               the workstation itself (such as height of the work surface, location of the
                               keyboard and mouse, and height of the monitor). The questionnaire also
                               asks for information about the presence of risk factors for particular parts
                               of the body. As a part of this questionnaire, the employee is asked to
                               provide information about what tasks he or she believes contributed to the
                               discomfort. A less detailed version of this questionnaire is used for
                               evaluations triggered by reports of discomfort or requests for assistance.



                               Page 64                           GAO/HEHS-97-163 Private Sector Ergonomics Programs
                          Appendix III
                          The Ergonomics Program at AEFA
                          Headquarters, Minneapolis, Minnesota




                          In some cases, AEFA has done job analysis for problem jobs identified
                          through the discomfort survey. Officials said a job analysis studies the
                          actual tasks of the job and work organization and determines whether
                          actual job tasks should be changed to reduce hazards. AEFA analyzed the
                          CSO job categories several years ago, a task that included interviewing the
                          employees working in these positions, evaluating the job tasks, and
                          determining what type of equipment and furniture would be best suited for
                          these tasks. Additionally, the ergonomics staff is currently looking for
                          controls that reduce or eliminate the hazards associated with a mailroom
                          job that requires lifting often heavy packages out of a large mail bin.
                          Officials said they would like to do more job analysis so that problem jobs
                          could be addressed on a broader basis. However, this would require
                          additional resources that are not necessarily available.

Process Used to Develop   AEFA  officials described their process for developing controls for problem
Controls                  jobs as “informal” and using in-house resources. AEFA takes this approach
                          to have the resources available to provide some type of control for every
                          job it evaluates.

                          The ergonomics specialist uses the information obtained during the
                          evaluation to develop and implement controls, often brainstorming with
                          the affected employee or relying on in-house expertise. Because most
                          employees covered by the program face similar computer-related hazards,
                          in many cases, controls have been developed by first determining whether
                          employees have the equipment available from the approved computer
                          accessories listing. If necessary, AEFA works with its real estate and
                          purchasing departments to design or obtain a piece of furniture or
                          equipment that is not already available in-house. If the ergonomics
                          specialist recommends controls such as taking rest breaks, the employee
                          and supervisor are supposed to work together to achieve this. If
                          adjustments to the employee’s workstation are required, the ergonomics
                          specialist will put in a requisition to the facilities department to adjust the
                          workstation, which is typically done within a week.

                          To ensure that these controls are effective over the long term, AEFA has
                          developed a database that contains the results of each workstation
                          evaluation performed. Each employee’s “profile” (that is, workstation
                          measurements, preferences such as left- or right-handed mouse,
                          appropriate monitor height, and equipment used) is kept in this database;
                          currently the database contains about 4,000 employee profiles. The
                          availability of this information means that the facilities department can set
                          up an employee’s workstation correctly the first time when an employee



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                                Appendix III
                                The Ergonomics Program at AEFA
                                Headquarters, Minneapolis, Minnesota




                                relocates. This ensures that employees continue to work in appropriately
                                designed workstations and eliminates “post-move” adjustments
                                (readjusting the workstation after the employee has moved in).

                                Officials said they follow up if employees continue to feel discomfort or if
                                injuries continue to be reported. For workers’ compensation cases, the
                                ergonomics specialist follows up monthly to update the questionnaire used
                                during the first evaluation. This iterative approach is important when
                                financial or organizational issues affect the implementation of controls.
                                For example, a number of employees still do not have adjustable furniture,
                                because it is not feasible from a cost perspective to replace all of the
                                existing furniture at once. Instead, AEFA is gradually providing this
                                furniture to more and more employees.

Types of Controls Implemented   AEFA has implemented a mix of controls, primarily focused on improving
                                the comfort of employees working with computers. In many cases, these
                                controls can be considered “low-tech” engineering controls, since they did
                                not change the job or the employee’s tasks. For example, AEFA has
                                provided ergonomic chairs to employees and adjusted workstations (for
                                example, adjusting work surfaces, moving equipment, repositioning
                                monitors, or providing corner work surfaces54). AEFA has also provided
                                articulating arm rests to selected employees. These arm rests fasten to the
                                edge of the workstation and allow the employees to rest their forearms on
                                a moveable padded support while using the mouse.

                                AEFA has also used administrative controls, such as encouraging
                                employees to take stretch breaks and providing information and training.
                                For example, AEFA published guidelines that provide information about the
                                best colors to use on monitors for the best viewing. Many of the computer
                                accessories supplied serve as personal protection equipment—such as
                                wrist rests, foot rests, and holders to support documents referred to while
                                keying.55 AEFA has also provided information to managers about the
                                processes they should follow to ensure employees receive training.
                                However, several employees said workload demands and cubicle size
                                affected their ability to implement certain ergonomic practices, such as
                                taking breaks or putting their monitors in an appropriate location.

                                54
                                  A corner work surface creates a diagonal surface on which employees can place their keyboards,
                                providing employees additional comfort while using the computer and increased access to items on
                                either side of it.
                                55
                                 AEFA officials were not sure how to categorize these computer accessories. One official said they
                                may be a “blend” of administrative and engineering controls. For purposes of presentation, we are
                                categorizing these items as personal protective equipment because they are similar to padded gloves
                                or wrist supports, in that they provide a barrier between the employee and the hazard.



                                Page 66                                 GAO/HEHS-97-163 Private Sector Ergonomics Programs
                         Appendix III
                         The Ergonomics Program at AEFA
                         Headquarters, Minneapolis, Minnesota




Training and Education   Training is the cornerstone of AEFA’s program. Part of the reason training
                         plays such a major role in the program is that most of AEFA’s headquarters
                         employees work in an office environment and therefore face similar
                         computer-related hazards. Office ergonomics training is taught by the
                         ergonomics specialist for 1-1/2 hours every Thursday; this module has also
                         been built into orientation training for selected employees. The training
                         provides employees information on what they should do to make their
                         workstation more comfortable, including how they should adjust their
                         chairs and monitors, how they should use the phone, and the importance
                         of reporting symptoms and pains early. During this training, employees are
                         also measured so their workstations can be set up properly and are asked
                         to fill out the discomfort survey as well as the feedback survey on the
                         quality and effectiveness of the training. AEFA has also recently begun to
                         provide training on proper lifting techniques to employees who face
                         hazards associated with manual material handling.

                         To supplement this training, AEFA has provided written employee
                         guidelines and a video, which cover much of the same information as is
                         provided in the training. The ergonomics specialist also uses E-mail and
                         other electronic media to send out messages about ergonomics and the
                         availability of training.


Medical Management       AEFA’s ergonomics program has established links with its medical
                         management staff (in-house risk management officials as well as local
                         health care providers) to ensure early reporting and prompt evaluation of
                         injuries. Through the training and discomfort surveys discussed above,
                         AEFA emphasizes the importance of early reporting. The risk management
                         department, which is responsible for tracking workers’ compensation
                         costs, can also trigger a workstation evaluation by providing the First
                         Report of Injury form to the ergonomics staff when reported injuries are
                         believed to be due to ergonomic hazards.

                         To ensure prompt evaluation, AEFA has identified local health care
                         providers with expertise in diagnosing and treating MSDs that employees
                         can use if they desire.56 AEFA has also encouraged these health care
                         providers to visit the facility and become familiar with AEFA’s operations to
                         understand what AEFA employees do and how AEFA can accommodate any
                         medical restrictions.


                         56
                          While employees in Minnesota are allowed to select their own health care providers, AEFA officials
                         said that, in most cases, employees prefer to use the providers identified by AEFA because these
                         providers are knowledgeable about MSDs and typically can better serve the employees.



                         Page 67                                 GAO/HEHS-97-163 Private Sector Ergonomics Programs
                         Appendix III
                         The Ergonomics Program at AEFA
                         Headquarters, Minneapolis, Minnesota




                         AEFA  also uses transitional or restricted-duty assignments to return
                         employees to work as soon as appropriate and follows up on the
                         employees’ recovery once they return. AEFA has classified a number of jobs
                         as “temporary modified duty” positions, and officials said they have had a
                         positive experience with bringing previously injured employees back to
                         work. If an employee has been out for 10 days, AEFA contacts the health
                         care provider and suggests various light-duty jobs the employee might be
                         able to do. Once the employee has returned to work, the ergonomics
                         specialist conducts a workstation evaluation to ensure that work
                         conditions support whatever restriction the employee may have. AEFA
                         allows employees a 12-week transition period to ease back into the job
                         requirements, during which time the ergonomics specialist conducts
                         monthly follow-up. If it is determined that the employee cannot perform
                         the job tasks anymore, AEFA works with the employee to find another job,
                         within AEFA if possible.


                         AEFA officials said they are pleased with the results of the program, which
Results and Issues       they believed has helped reduce workers’ compensation costs for MSDs and
Related to Program       improve employee productivity and morale. However, they raised several
Performance              issues that complicated their ability to tie the results directly to program
                         efforts and that therefore should be considered when reviewing these
                         results.


Reductions in Workers’   As shown in figure III.1, AEFA reduced its costs for MSD workers’
Compensation Costs       compensation claims by about 80 percent (from about $484,000 to about
Associated With MSDs     $98,000) between 199257 and 1996. Because the program has to date
                         focused on employees who use computers in an office environment, AEFA
                         tracks MSDs by looking at “computer and mouse injuries” and other
                         “repetitive motion injuries not related to computer use.”58 Additionally, the
                         officials said the reduction in the average cost incurred for MSD claims
                         (from about $9,100 in 1992 to about $1,700 in 1996, as shown in fig. 3) is an
                         indication of AEFA’s emphasis on early reporting and treatment of injuries
                         before they become serious.


                         57
                          As more fully discussed in app. I, in most cases, we present data from the year before the full
                         implementation of the ergonomics program through 1996 in order to show changes that occurred
                         during the years of the program’s operation. Since AEFA’s program was fully implemented in 1993, we
                         present data beginning in 1992.
                         58
                          The “other” repetitive motion injuries at this time do not include those associated with stress, strain,
                         and lifting. Officials did not believe it was appropriate to include these injuries in their results data
                         because the ergonomics program has only recently begun to focus on these hazards.



                         Page 68                                   GAO/HEHS-97-163 Private Sector Ergonomics Programs
                                      Appendix III
                                      The Ergonomics Program at AEFA
                                      Headquarters, Minneapolis, Minnesota




Figure III.1: Workers’ Compensation
Costs for MSDs at AEFA, 1992-96       Total Dollars for MSD Claims (in Thousands)
                                      500    484

                                      450

                                      400

                                      350

                                      300

                                      250
                                                                208
                                      200

                                      150
                                                                                    98
                                      100
                                                       65                 60
                                       50

                                        0

                                              1991      1992      1993      1994     1995
                                              Policy Year



                                      Notes: AEFA’s data system is based on “policy years.” A policy year begins on Sept. 30 and ends
                                      on Sept. 29. In other words, policy year 1991 is the period from September 30, 1991, through
                                      Sept. 29, 1992. As a result, for this discussion, we refer to policy year 1991 as “1992,” policy year
                                      1992 as “1993,” and so on.

                                      Data include headquarters and field staff, since data are not available for headquarters
                                      employees only.

                                      Source: AEFA’s workers’ compensation database.




                                      AEFA officials said several factors have affected AEFA’s ability to reduce
                                      costs further and account for some of the yearly fluctuations. For
                                      example, the spikes in workers’ compensation costs for MSDs in 1994 and
                                      1996 (that is, policy years 1993 and 1995) may be the result of the
                                      emphasis on closing open cases. Additionally, there is often a lag between
                                      the time an injury occurs and when the costs appear. Costs also are
                                      significantly affected by any big claim, as is evident in 1996 (policy year
                                      1995), when several major cases required surgery. Additionally, AEFA
                                      officials said the increase in claims in the first year after the program was
                                      fully implemented may be at least partly attributed to increased employee
                                      awareness. AEFA has also experienced a significant increase in staffing
                                      levels since 1988 as well as increased workloads. Officials said that the




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                             Appendix III
                             The Ergonomics Program at AEFA
                             Headquarters, Minneapolis, Minnesota




                             reductions AEFA has achieved should be considered in light of these
                             factors.

                             AEFA officials also said there is some question about what types of injuries
                             should be considered MSDs. As long as there is no agreed-upon definition, it
                             is sometimes difficult to know what to track and how to distinguish MSDs
                             from other injuries. Although ergonomics staff rely on their workers’
                             compensation database rather than on the OSHA 200 log data, they said the
                             database in the past has not allowed them to break out data by geographic
                             location or department or to track lost workdays. Working with its insurer,
                             AEFA enhanced the database so that, starting in 1997, it now provides this
                             information.


Reductions in Injuries and   As a financial institution, AEFA is not required to maintain the OSHA 200 log.
Illnesses According to the   However, AEFA’s safety department does keep the OSHA 200 log voluntarily
OSHA 200 Log                 because AEFA is among the universe of employers included in BLS’ Survey
                             of Occupational Injuries and Illnesses, which collects data (from the OSHA
                             200 log) about workplace injuries and illnesses.59 However, the
                             ergonomics staff at AEFA did not use the OSHA 200 log to track program
                             progress for several reasons. First, because the ergonomics staff were not
                             responsible for monitoring the log, they were uncertain of how the data
                             were input onto the log. Second, ergonomics staff believed it was more
                             efficient to use the workers’ compensation database, since it allowed
                             ergonomics staff to track injuries, claims, and costs. Finally, the safety
                             officials who maintained the log said there is confusion about how to
                             categorize ergonomically related injuries; for example, back injuries are
                             not typically coded under the repetitive trauma category.


Improvements in              Facility management officials said the ergonomics program has
Productivity, Quality, and   contributed to increased productivity and quality of work as well as
Morale                       employee morale. AEFA’s annual discomfort surveys have shown significant
                             declines in the number of employees reporting discomfort in numerous
                             body parts, including head, neck, back, shoulders, elbows, and wrists,
                             between 1993 and 1996.60 Furthermore, according to results from
                             numerous feedback surveys filled out by employees who have attended

                             59
                               Because OSHA 200 data were not available before 1994 and the facility did not maintain the data
                             necessary to calculate injury and illness incident rates, we did not include AEFA’s OSHA 200 log data
                             in this report.
                             60
                              For example, in 1993, about three-quarters of employees surveyed reported headaches and
                             discomfort in the neck and back. In 1996, only about one-third of surveyed employees reported these
                             symptoms.



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Appendix III
The Ergonomics Program at AEFA
Headquarters, Minneapolis, Minnesota




training since 1994, between 80 and 90 percent of employees believed that
learning about ergonomics was an effective use of their time, and most
indicated they planned to change some work habits on the basis of
information received from the training.

Because AEFA has not, to date, tracked the direct effects of the program on
productivity and quality, officials said it would be very difficult to pinpoint
any changes that resulted directly from the ergonomics program.
However, in an effort to establish whether discomfort affects employee
productivity, AEFA has revised its discomfort survey to ask employees the
extent to which they believe their discomfort affects their productivity.
The ergonomics staff hopes to use these results in future assessments of
the ergonomics program’s effect on productivity.




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Appendix IV

The Ergonomics Program at AMP,
Electronic Connectors Manufacturing
Facility, Tower City, Pennsylvania
                     AMP Incorporated, which began operation in 1941, is a manufacturer of
Background           electrical and electronic connection devices. AMP supplies connectors to a
                     wide variety of industries, including automotive, computer and office
                     equipment, and consumer and home electronics industries. AMP employs
                     40,800 employees in 212 facilities, with subsidiaries in 40 countries.

                     The Tower City facility, which began operation in 1972, stamps metals
                     with mechanical presses to form electronic terminals and connectors. The
                     majority of employees are die machinists and mechanics. The dies are
                     metal blocks, shaped through a grinding process, that fit into the
                     mechanical presses for use in stamping connectors into any one of a wide
                     variety of forms, depending upon the particular application of that
                     connector. Current employment at the Tower City facility is approximately
                     300. None of the workforce is unionized.

                     AMP’s  corporate culture allows for a decentralized approach that provides
                     business groups61 and local facilities flexibility to organize safety and
                     health activities in order to achieve production goals. As a result, a lot of
                     variation in operations exists among facilities, and this is reflected in the
                     ergonomics efforts. This variation in ergonomic programs across facilities
                     is also attributed by AMP management to business conditions, which affect
                     the level of investments for ergonomics, as for any other initiative, and to
                     local cultural and regulatory conditions. For example, facilities located in
                     states where some types of MSDs are not compensable may have less
                     incentive to reduce these injuries.


                     The ergonomics program at Tower City was fully implemented as of 1993,
Initiating the       when the facility formed an ergonomics team. The team was formed in
Ergonomics Program   response to the global safety department’s promotion of ergonomics
at Tower City        efforts across the company out of its concern regarding rising workers’
                     compensation costs for MSDs. The strategy of the global safety department
                     was to promote and train local ergonomic task teams in each of AMP’s
                     facilities.

                     AMP’s  ergonomics efforts, including those at Tower City, appear to have
                     been evolving since the late 1980s, when the global safety department
                     began offering ergonomics training courses. Corporate productivity
                     initiatives were also being launched, and business groups across AMP were



                     61
                      AMP is organized by business groups. For example, the Tower City facility is part of the Consumer
                     Products Business Group.



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                        Appendix IV
                        The Ergonomics Program at AMP,
                        Electronic Connectors Manufacturing
                        Facility, Tower City, Pennsylvania




                        forming teams of employees to get them more involved in production
                        activities and to identify production problems.


                        The heart of the ergonomics program at Tower City is the value-added
Structure and Core      manufacturing (VAM) team for ergonomics.62 This team is composed of
Elements of the         employees from a wide variety of departments—including tool and die
Program at Tower        making, maintenance, and packaging—and is led by an industrial engineer.
                        The team is responsible for identifying problem jobs and developing
City                    controls.

                        The global safety department serves in a consulting capacity to the
                        different teams and facilities across AMP for all safety and health issues,
                        including ergonomics. The global safety department has a total of nine
                        staff, six of whom are professional staff. In addition, the department
                        provides training and administers the corporationwide safety audits of all
                        facilities, of which an assessment of ergonomic activities is a small part. In
                        addition to global safety staff, there are environmental safety and health
                        coordinators across AMP who report to individual facilities and business
                        groups as well as overseas operations.


Management Commitment   Management commitment to the ergonomics program at Tower City is
                        demonstrated in a number of ways. Primary among them is the assignment
                        of staff—to the ergonomics team—specifically to address ergonomic
                        hazards.

                        Corporationwide accountability mechanisms are in place in the form of a
                        safety audit, the recent integration of an overall safety goal into AMP’s
                        pay-for-performance system, and recommended criteria to help develop
                        performance measures. An AMP-wide safety audit, the Safety Assessment of
                        Facility Excellence (SAFE), helps ensure accountability for the ergonomics
                        program, among other safety efforts, and can be used by facilities to
                        conduct self-assessments of their safety programs. For example, SAFE
                        includes questions on whether an ergonomics team has been established,
                        routine workplace inspections for ergonomic opportunities are being
                        conducted, and specific worksites where MSD risks or symptoms have been
                        identified are being evaluated. Additionally, the 1997 overall safety goal of
                        one accident involving lost or restricted days per 100 employees has been

                        62
                          The ergonomics VAM team is one of a total of 21 VAM teams and two product-focused teams at
                        Tower City alone. These teams were formed to get employees more involved in production activities,
                        and they operate similarly, using performance agreements as a way to track progress on projects the
                        team decides to undertake.



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Appendix IV
The Ergonomics Program at AMP,
Electronic Connectors Manufacturing
Facility, Tower City, Pennsylvania




integrated into AMP’s pay-for-performance system. This goal was based on
the experiences of other employers in this industry who are members of
the National Safety Council. Finally, suggested criteria or activities, some
of which are ergonomic-specific, were recommended by the global safety
department to the local facilities to help them develop
pay-for-performance measures that are meaningful at the local level and
that contribute toward this overall safety goal. An ergonomic criterion, for
example, is whether or not ergonomic teams have been recruited and
trained at each local facility to evaluate job tasks.

Ergonomic principles are also integrated into the purchasing of tools,
equipment, and furniture and the design of new facilities. Tower City
works closely with its suppliers to test and evaluate a variety of ergonomic
tools and equipment before purchasing these items. For this purpose,
Tower City has set up Ergonomic Prototype Work Centers in virtually
every work area to test new products and controls, and to obtain
employee acceptance of new controls. AMP’s corporate facilities services
center has developed a catalog of furniture that is modular and adjustable,
and global safety has recommended that individual facilities order items
from this catalog. In designing a new, larger facility in nearby Lickdale,
Pennsylvania, where operations at Tower City and another facility will be
combined, focus groups were formed to provide input so that ergonomic
principles, among other design considerations, would be addressed.

Resources are also made available for the ergonomics program. The team
leader said that most of the team’s suggestions for controlling problem
jobs are approved at the facility level and that a written justification and
approval from a higher level of management are needed only when a
capital investment of $2,000 or more is involved (which is the case for all
investments). When developing the cost justification, the ergonomics team
routinely includes an estimate of the cost of MSDs should controls not be
implemented.

AMP has a written program in the form of a section in its safety manual,
although this document is not key to program operations at the facility
level because facilities are given considerable flexibility to implement
ergonomics programs as they see fit. This section in AMP’s “124
Specification” identifies specific areas of responsibility to be assumed by
local facilities and various departments to address ergonomic hazards. For
example, local facilities are encouraged to perform routine, periodic
workplace inspections for ergonomic hazards as part of the facilities’
ongoing loss prevention efforts, and the facility services department is



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                            Appendix IV
                            The Ergonomics Program at AMP,
                            Electronic Connectors Manufacturing
                            Facility, Tower City, Pennsylvania




                            responsible for the selection of adjustable office furniture. In addition, the
                            global safety department is in the process of developing guidelines that
                            include ergonomic activities to help local facilities develop or improve
                            their safety programs.


Employee Involvement        The ergonomics VAM team drives the effort at the Tower City facility.
                            About 12 employees (referred to as “associates”) serve as team members
                            and are responsible for identifying and prioritizing problem jobs as well as
                            developing controls for these jobs. Both the team leader, who is an
                            industrial engineer, and the secretary of the VAM team are elected. One
                            member of the ergonomics team is assigned to each project that the team,
                            after prioritizing, agrees to take on. In this way, projects are “championed”
                            by individual team members. The team meets biweekly during work hours
                            because weekly meetings were found to be too time consuming.

                            Employees are involved in an ad hoc fashion as well. Any employee can
                            choose to participate on the ergonomics team on a project-by-project basis
                            if, for example, the team is trying to develop controls for that employee’s
                            job. Many employees on problem jobs are interviewed by members of the
                            team who are investigating the problem jobs, and these employees are the
                            source of ideas for many of the controls developed.

                            Procedures have been established so employees can directly access
                            ergonomic services, although these procedures are very informal at this
                            facility. Employees can request that the ergonomic team look at their job
                            by raising their concerns with a member of the team, their representative
                            on the local safety committee, their supervisor, or their human resources
                            representative. This is done by word of mouth. Although an analysis of the
                            job is not automatically triggered, the job or task is added to a list of
                            problem jobs, which the team then prioritizes. (A discussion of
                            prioritization appears below.) In addition, the ergonomics team leader
                            “walks the floor,” so he is accessible to employees should they be
                            experiencing discomfort. As evidence of employee interest, the team
                            leader said many associates voice their ideas informally for how jobs
                            might be controlled or changed to reduce exposure to ergonomic hazards.
                            The facility also has a suggestion system that awards employees for
                            suggestions regarding any aspect of the facility’s operations, including
                            ergonomic improvements.


Identification of Problem   There are several ways in which the ergonomics team learns that a job
Jobs                        might be a problem. The following methods for identifying problem jobs


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                              Appendix IV
                              The Ergonomics Program at AMP,
                              Electronic Connectors Manufacturing
                              Facility, Tower City, Pennsylvania




                              are incidence-based; that is, they are based on employee reports of injury
                              or discomfort or employee requests for assistance:

                          •   Information from incident reports, which are completed whenever an
                              accident or “near miss” incident63 has occurred or whenever an employee
                              reports symptoms to a supervisor or the facility nurse (who is a member of
                              the ergonomics team), is provided to the ergonomics team if ergonomic
                              hazards appear to be involved.
                          •   Periodic walk-through audits by AMP’s third-party insurance administrator
                              alert the facility to opportunities to address ergonomic hazards. In some
                              cases, insurance representatives may look specifically at those areas
                              where workers’ compensation costs are high.
                          •   Employees can bring up any discomfort they are experiencing with
                              members of the ergonomics team, their representative on the local safety
                              committee, their supervisor, or their human resources representative;
                              ergonomics team members themselves identify problem jobs on the basis
                              of symptoms they are experiencing or complaints they have heard from
                              fellow employees. The suggestion system also may provide information on
                              potential problem jobs. Requests to the ergonomics team to address a
                              problem job can also come from management of the facility or business
                              group, the departments, the local safety committee, or one of the other 17
                              VAM teams at Tower City.


                              Prioritization of problem jobs is done by the ergonomics team. Once the
                              ergonomics team is alerted that a job may be a problem, the team
                              prioritizes which jobs it will analyze. Each team member is asked to
                              identify the two or three jobs he or she feels are most important to
                              address. The problem jobs are then ranked on the basis of how many team
                              members have identified them as important. Jobs in which MSDs have
                              already occurred are typically given the highest priority. Because the team
                              identifies its own priorities, this process also serves the purpose of
                              keeping the team focused and interested. As indicated previously,
                              individual team members are assigned to “champion” each selected
                              project.


Analyzing Problem Jobs        Facility officials described their process for analyzing problem jobs and
and Developing Controls       developing controls as “intentionally flexible” and “informal.” Analysis of a
                              problem job might involve simply analyzing a particular job element or
                              task that is thought to be the source of the problem. However, if a problem

                              63
                                A near miss incident is one in which significant property damage or serious injuries could have
                              resulted.



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                               Appendix IV
                               The Ergonomics Program at AMP,
                               Electronic Connectors Manufacturing
                               Facility, Tower City, Pennsylvania




                               job is more complex or labor intensive, Tower City will undertake a more
                               detailed job analysis.

                               Members of the team and management at the facility and corporate levels
                               all emphasized that developing controls is not “rocket science” and that
                               the answers typically come from employees on the production floor. The
                               process of developing controls was described as “iterative” and involving
                               “continuous improvement.” The ergonomics team leader said that its work
                               is never done, because new problem jobs or tasks are always being
                               identified and controls initially introduced for problem jobs are not always
                               adequate. A mix of controls is employed, but many were described by
                               facility officials as “low-tech” engineering controls.

Process Used to Analyze Jobs   To analyze a problem job, a one-page “Ergonomic Evaluation Form,” is
                               administered to the employee on the problem job. The form is tailored to
                               that specific job, and asks “yes/no” questions about the employee’s ease
                               and comfort when performing certain job tasks. After reviewing this form,
                               a member of the ergonomics team interviews the employee and observes
                               the employee performing the job. This Ergonomic Evaluation Form was
                               initially longer and more complex but was subsequently simplified to
                               encourage employees to fill it out. As an incentive, those who fill out this
                               form are provided the opportunity to test any new equipment or tools, and
                               will be involved in the final decision about which equipment or tools to
                               purchase. For jobs involving keyboarding, a one-page “yes/no” workstation
                               checklist is used to record observations such as whether the chair and
                               keyboard are adjusted properly, or whether there is adequate variety in
                               tasks performed throughout the day.

                               If a problem job is more complex or labor intensive, Tower City will
                               undertake a more detailed job analysis, which may involve videotaping the
                               job and collecting more documentation. According to the ergonomics
                               team leader, problem jobs are videotaped whenever possible because the
                               team finds this helpful for identifying the ergonomic hazards of a job and
                               possible controls. For example, the team has videotaped jobs in the
                               re-reeling department, where connectors and terminals manufactured at
                               this facility are wound onto reels for packaging and distribution; the
                               packaging department, where boxes are stretch-wrapped for shipping; and
                               the machine shop, where the grinding and milling of dies takes place.

                               Additional documentation is collected to develop controls for these
                               problem jobs using the “Job/Task Evaluation” form. This form is several
                               pages long and provides space to record more detailed observations about



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                          Appendix IV
                          The Ergonomics Program at AMP,
                          Electronic Connectors Manufacturing
                          Facility, Tower City, Pennsylvania




                          the adequacy of the workspace, environmental conditions, and hand tools
                          as well as for comments regarding possible controls. A physical
                          assessment survey may also be administered to capture frequency of
                          discomfort in various body parts. This was done in the re-reeling
                          department because that department historically had higher numbers of
                          MSDs.


                          Tower City also used “process mapping” sometimes, which involves
                          breaking down the steps of a job process and then, on the basis of that
                          information, developing a new method of performing that same job that
                          eliminates unnecessary steps. Although the focus of this type of job
                          analysis is usually improving productivity, this analytical tool is recognized
                          by the ergonomics team as helping the facility make important ergonomic
                          improvements.

Process Used to Develop   The controls themselves are developed informally, through
Controls                  “brainstorming” by the ergonomics team members using the information
                          collected from analyzing the job, interviewing employees, and suggestions
                          from employees on the production floor.

                          Although the ergonomics team takes the lead in developing controls, it has
                          access to in-house engineering support. For example, the team had
                          developed a prototype cutoff device to reduce stress on employees from
                          ripping paper placed between layers of connectors as they are wound onto
                          reels. Because this device was found to be inadequate, the ergonomics
                          team has requested assistance from the engineering group to develop a
                          fully automated paper cutter.

                          Although Tower City officials said many controls were developed
                          internally, there were instances in which outside resources were integral.
                          For example, the Tower City facility arranges with vendors or suppliers to
                          provide tools and equipment at no cost to the facility so the facility can
                          test the product before making a purchase. Through its Ergonomic
                          Prototype Work Centers, which are set up within each work area, these
                          tools and equipment are then evaluated. By creating an Ergonomic
                          Prototype Work Center in the tool and die work area, the ergonomics team
                          enabled employees to experiment with different tools and different ways
                          of arranging tools to eliminate awkward reaching. The facility now
                          suspends the tools by magnetic strips in easy arm’s reach above the
                          workstation. Also, tools are organized by specific jobs to make it easier for
                          the employee to locate the appropriate tool. In addition, the ergonomics
                          team also uses electronic media, including the Internet, to obtain



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Appendix IV
The Ergonomics Program at AMP,
Electronic Connectors Manufacturing
Facility, Tower City, Pennsylvania




information on ergonomics and available tools. The ergonomics team
leader then distributes this information throughout the facility, both for
education and awareness purposes as well as for ideas for controls. In
select instances, the facility may also use the services of its third-party
administrator’s loss control engineers to help identify controls, such as in
the re-reeling department (see app. II).

The ergonomics team tries to address in some way every job that has been
identified as a problem job. According to AMP officials, small and focused
efforts to develop and implement controls were important in achieving
early successes and convincing employees and management alike that the
ergonomics program was worthwhile. Some of the initial projects of this
team involved little or no capital investment, were relatively easy to
develop and implement, and were inherently good candidates for success.

The process of developing and implementing controls was described by
facility officials as “iterative” and involving “continuous improvement.”
Controls initially introduced for problem jobs might not be adequate or
may introduce new problems, such as slowing operations down, which
underscores the importance of going back to monitor the job once the
controls have been introduced to see if they are working and employees
have accepted them. So, while controls already implemented have helped
to reduce reports of MSDs in the re-reeling department, the ergonomics
team continues to work to improve this job. For example, the introduction
of vacuum lifts to lift boxes from the conveyor to a skid for packaging
slowed the operator down while he or she manipulated the boxes so they
were properly oriented before being placed on the skid. As a result, the
ergonomics team is researching other, perhaps more efficient, possibilities
for safe handling. The team also continues to identify other solutions to
problem jobs and tasks, such as redesigning racks where reels are stored
so that employees are not lifting the heavy reels as high.

This facility has instituted a formal follow-up process to determine
whether or not controls introduced on problem jobs are working. The
ergonomics team administers a postevaluation form, the same one-page
form administered before controls were introduced, to document whether
or not the ease and comfort of employees performing that job or job task
have improved. Formal follow-up also occurs through performance
agreements, which are drawn up for each major project undertaken by the
ergonomics team and posted in a public area. These performance
agreements require the team to document its desired and actual results for
comparison, as well as its standards of performance or accountability. For



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                                Appendix IV
                                The Ergonomics Program at AMP,
                                Electronic Connectors Manufacturing
                                Facility, Tower City, Pennsylvania




                                example, one desired result was to establish a procedure for employees to
                                obtain ergonomic chairs, with a performance standard of securing at least
                                one chair per quarter. The ergonomics team documented the success of
                                this project by developing criteria for individual employees to qualify for
                                ergonomic seating, selecting a line of products, and establishing a system
                                by which the team identifies seating requirements and counsels individual
                                employees regarding appropriate ergonomic chairs. Sometimes the
                                ergonomics team will also circulate a written comment sheet to employees
                                to elicit feedback on the controls that have been introduced, as the team
                                did for the re-reeling job.

                                In addition, informal follow-up occurs through ongoing review of medical
                                reports and walk-throughs conducted by members of the ergonomics team
                                to determine whether or not employees continue to experience problems
                                in jobs where controls have been introduced.

Types of Controls Implemented   A mix of controls is employed, but many were described by facility
                                officials as “low-tech” engineering controls. For example, this facility uses
                                mechanical arms to maintain tension of electronic connectors as they are
                                reeled and has modified the tool and die workstations so that tools are
                                suspended within easy reach.

                                Sometimes administrative controls are used when engineering controls are
                                difficult to implement or do not completely eliminate all ergonomic
                                hazards. For example, in the re-reeling job, employees are rotated every 2
                                hours so they are not reeling the same product over long periods of time.


Training and Education          General awareness training is provided only to members of AMP’s local
                                ergonomics task teams (including Tower City’s ergonomics team). This
                                training consists of a half-day course offering a basic overview of
                                ergonomic principles. Global safety conducts this course and also follows
                                up to see how well the teams are implementing their programs.

                                Training provided to all employees is informal—through distribution of
                                literature and promotion of the activities of the ergonomics team. Also,
                                Tower City integrates ergonomics into ongoing worker training on all
                                equipment. This is done by the facility’s equipment trainer, who serves as a
                                member of the ergonomics team and is responsible for teaching all
                                employees proper work practices and how to avoid ergonomic hazards. In
                                addition, training is provided to each employee on a particular job when
                                that job has been changed to reduce exposure to ergonomic hazards.



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                     Appendix IV
                     The Ergonomics Program at AMP,
                     Electronic Connectors Manufacturing
                     Facility, Tower City, Pennsylvania




                     Tower City emphasizes focused, specialized training for employees based
                     on their respective roles in addressing these hazards. Training for
                     engineers, supervisors, and members of the ergonomics team is offered
                     through AMP’s Engineering Education Program and conducted by global
                     safety staff. The courses include an “Introduction to Ergonomics,” which
                     covers basic ergonomic design principles for machines, tooling, and
                     workstations and the benefits of ergonomic design in relation to corporate
                     strategic goals. An “Advanced Human Factors Workshop” offers in-depth
                     discussion of human factors principles in design and task analysis. This
                     course includes workshops in analyzing facility loss trends, conducting job
                     analysis, implementing controls, and computing return on investment for
                     management reports.

                     Global safety has recently started to offer training in behavior-based safety
                     management at several facilities. This training is intended to help staff
                     identify the root cause of behaviors that lead to accidents or contribute to
                     MSDs. This training will also cover how to document savings from changing
                     behaviors.

                     Because it has had a good business year, Tower City has been able to meet
                     its targets for training this year. However, global safety staff have found
                     training participation is affected by business conditions. In addition,
                     sometimes it is difficult to justify training, including ergonomics training,
                     during work hours. The result is that courses are often offered in the
                     evenings, which can also limit participation.


Medical Management   Strong linkages between Tower City’s ergonomics program and medical
                     management staff have been established to ensure early reporting and
                     prompt evaluation. An occupational nurse serves the Tower City facility
                     and two other facilities. This nurse, along with other AMP nurses, reports to
                     AMP’s department responsible for all health services. The nurse and
                     supervisors try to document whether the source or nature of injuries is
                     ergonomic-related. The nurse completes a medical report for every
                     accident for which medical treatment is required, and space is provided
                     for descriptive information to capture whether the problem may be related
                     to an ergonomic hazard. Incident reports are also completed by the direct
                     supervisor and reviewed by several managers before being sent to global
                     safety for analysis. Poor workstation design and incorrect use of
                     equipment or tools are among the hazardous condition categories that can
                     be indicated. These reports are regularly reviewed by the local safety




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                     Appendix IV
                     The Ergonomics Program at AMP,
                     Electronic Connectors Manufacturing
                     Facility, Tower City, Pennsylvania




                     committee and the ergonomics team, and the nurse, as a participant in
                     both groups, calls attention to problems related to ergonomic hazards.

                     Although most of the care provided for MSDs is through referral to local
                     health care providers, a list of several area physicians, known by AMP’s
                     insurance administrator to be knowledgeable about MSDs and familiar with
                     AMP’s operations, is provided to injured employees. The nurse works
                     closely with these physicians when an employee is diagnosed with an MSD
                     to develop appropriate treatment and to identify restricted- or light-duty
                     jobs. Nurses and occupational therapists employed by the insurance
                     administrator are also available to assist the facility nurse. These nurses
                     will, on occasion, observe the employee doing the job in question to help
                     the physician determine the exact nature of exposure. In addition, the
                     facility nurse told us she conducts informal walk-throughs to increase her
                     familiarity with the jobs and associated risks. Facility tours are also
                     provided to physicians in the community.

                     Tower City has a return-to-work policy to reduce workers’ compensation
                     costs. Finding restricted- or transitional-duty jobs has not been difficult at
                     this facility because there have never been many employees on this type of
                     duty, according to facility officials. Only three staff are currently on
                     restriction. In addition, Tower City can also bring employees in on half
                     shifts or restricted hours, and there are many opportunities for temporary
                     assignments because of the variety of jobs within each department. In fact,
                     this facility has always been able to place an injured worker in a restricted
                     job within his or her same department.64


                     AMP  officials said they were generally satisfied with the results of Tower
Results and Issues   City’s ergonomics program, which has sought to improve worker safety
Related to Program   and health through reduced injury rates and lower workers’ compensation
Performance          costs. However, officials raised a number of issues associated with Tower
                     City’s ability to assess program performance. Global safety officials said
                     that the identification of “metrics” by which to measure progress in safety
                     and health has been a challenge for the company. This difficulty prompted
                     this department to work to introduce safety goals into AMP’s
                     corporationwide pay-for-performance system and to solicit local facilities
                     to help develop meaningful measures.




                     64
                      As a corporation, however, AMP has faced some problems finding light-duty work for all its injured
                     employees and has faced some resistance from employees about its return-to-work emphasis.



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                                      Appendix IV
                                      The Ergonomics Program at AMP,
                                      Electronic Connectors Manufacturing
                                      Facility, Tower City, Pennsylvania




Reductions in Workers’                Workers’ compensation data provide some evidence that the ergonomics
Compensation Costs                    efforts at Tower City are helping to reduce costs associated with MSDs. To
Associated With MSDs                  capture MSDs, Tower City tracks sprains and strains in which the cause of
                                      the injury is lifting, repetitive motion, pushing, or pulling. As shown in
                                      figure IV.1, Tower City has achieved a reduction in workers’ compensation
                                      costs for MSDs from about $73,000 in 199365 to about $28,000 in 1996.
                                      Additionally, during this same time period, the average cost for each MSD
                                      claim declined from $6,601 in 1993 to $2,512 in 1996 (see fig. 3).


Figure IV.1: Workers’ Compensation
Costs for MSDs at the AMP Facility,   100      Total Dollars for MSD Claims (in Thousands)
1993-96


                                       75      73




                                       50



                                                                              28
                                       25

                                                         12
                                                                   6

                                           0

                                                 1993     1994         1995    1996
                                                 Calendar Year



                                      Source: AMP’s workers’ compensation database.




                                      While AMP officials believe these data suggest improvements at the facility,
                                      officials emphasized it would be difficult to attribute all improvements to
                                      the operation of the VAM team, given other contributing factors. First, there
                                      is a limited number of available years of workers’ compensation data
                                      available, and officials said it may take several years before real changes
                                      occur. Second, officials said there is often a lag in workers’ compensation

                                      65
                                       As discussed in app. I, we attempted to present data for the year prior to the program’s full
                                      implementation through 1996 for each facility. However, workers’ compensation data for 1992, the
                                      year prior to the program’s full implementation, were not comparable to data for later years.
                                      Therefore, we present data for the AMP facility for the years 1993 to 1996.



                                      Page 83                                      GAO/HEHS-97-163 Private Sector Ergonomics Programs
                             Appendix IV
                             The Ergonomics Program at AMP,
                             Electronic Connectors Manufacturing
                             Facility, Tower City, Pennsylvania




                             data, and the injury may have occurred years before the costs show up in
                             the data. This sometimes makes it difficult to interpret changes in workers’
                             compensation costs.


Reductions in Injuries and   Trends in overall injuries and illnesses from the OSHA 200 log are important
Illnesses According to the   because MSDs account for a significant portion of all injuries and illnesses
OSHA 200 Log                 at our case study facilities and because these data are what OSHA looks at
                             when inspecting a facility. From 1993 through 1996, the facility’s rate of
                             injuries and illnesses for every 100 employees, known as the incidence
                             rate, declined from 12.8 to 7.1 (see fig. 4). The incidence rate for 1995 of
                             5.4 is lower than the 1995 industry average of 7.1 for manufacturers of
                             electronic connectors, according to the most recent available data.
                             Additionally, Tower City reduced the number of lost days by 78 for every
                             100 employees from 1993 through 1996. In contrast, during the same
                             period the number of restricted days increased by 21 for every 100
                             employees, which, in fact, may be the consequence of bringing more
                             injured workers back to work (see fig. 2). However, the team generally
                             does not use the OSHA 200 data to assess its progress, preferring instead to
                             rely on the facility nurse to do so because she is knowledgeable about
                             recording and interpreting the data.


Improvements in              Tower City has also established a linkage between ergonomic investments
Productivity, Quality, and   and productivity or quality improvements. By examining production
Morale                       bottlenecks, this facility has identified ergonomic hazards that contribute
                             to the production problem. The facility used an analytical tool called
                             “process mapping,” which involves describing each step of a job process
                             and then, on the basis of that information, developing a new method of
                             performing that same job process that eliminates unnecessary steps.
                             Process mapping enables the facility to demonstrate how comparatively
                             fewer steps (less time and shorter distances) are required to perform the
                             same activity. For example, employees used to have to manually search
                             through bins filled with numerous channels, or attachments, to locate,
                             align, and fix a particular channel on a die to guide a newly manufactured
                             terminal as it was re-reeled. Through process mapping, a new way of
                             attaching the matching channel to the die earlier in the process was
                             identified. In another application of process mapping, employees no longer
                             have to crawl under the press to feed a vacuum hose to remove scrap
                             material after connectors are stamped. A new extraction system has been
                             installed underneath the press that automatically removes remnant or




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Appendix IV
The Ergonomics Program at AMP,
Electronic Connectors Manufacturing
Facility, Tower City, Pennsylvania




scrap metals. This improvement has also reduced the facility’s scrap rate
and improved the quality of recovered metals.

Worker morale has also improved, as reflected by employee interest and
involvement in the activities of the ergonomics team. In general, the
ergonomics program has been a vehicle to get employees more involved in
how their jobs are performed, according to the team leader, as evidenced
by employees’ significant use of the “suggestion system.”




Page 85                           GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix V

The Ergonomics Program at Navistar,
Springfield Assembly Facility, Springfield,
Ohio
                Navistar International Transportation Corp. manufactures heavy- and
Background      medium-duty trucks, school buses, diesel engines, and service parts.66
                Navistar has 10 facilities in the United States, Canada, and Mexico,
                employing about 15,000 employees worldwide. The Springfield Assembly
                Facility assembles the heavy- and medium-duty trucks. Originally designed
                to produce pick-up trucks, the facility was built in 1967 and currently
                employs about 4,000 employees, most of whom work on the production
                floor assembling truck parts. About 80 percent of Navistar’s workforce is
                unionized and under contract with the United Auto Workers (UAW). Some
                office employees and security personnel are also unionized at the local
                level.

                The culture at Navistar has influenced the implementation of the
                ergonomics program. For example, the UAW bargaining agreement requires
                each facility to have an ergonomics program that includes employee
                involvement in the identification of hazards and selection of control
                methods; job analysis to identify ergonomic risk factors and target
                ergonomic interventions; training for employees; and active involvement
                of the medical department in the identification of problems, medical
                evaluation, treatment, rehabilitation, record keeping, and job placement of
                restricted workers, among other requirements.

                Navistar’s facilities have flexibility in how they carry out their ergonomics
                programs and achieve bargaining agreement requirements, safety and
                health standards, and injury reporting requirements. Thus, the programs
                differ somewhat from one facility to another. For example, only three of
                Navistar’s facilities have full-time ergonomists to lead the ergonomics
                programs. Additionally, because of experiences during program evolution,
                the membership of the ergonomics committees may differ from one
                facility to the next.

                Local facility conditions also affect program implementation. A key feature
                of Navistar’s products is that they can be customized; this means that
                production lines and processes at the Springfield facility can change
                frequently. Additionally, because there is cyclical demand for any
                particular product, production line speeds can vary significantly. Both of
                these factors mean that jobs or job tasks may change every few months.
                This poses challenges for Springfield to identify particular problem jobs
                and ensure that controls are effective over the long term. Additionally,
                Springfield has hired relatively few new employees over the past 2

                66
                 Until 1984, Navistar operated under the name International Harvester, manufacturing primarily
                agricultural equipment.



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                     Appendix V
                     The Ergonomics Program at Navistar,
                     Springfield Assembly Facility, Springfield,
                     Ohio




                     decades, and over the past several years its staffing level has remained
                     fairly stable. As a result, the facility’s workforce is composed largely of
                     men whose average age is 50. While the collective experience of this
                     workforce helps to prevent injuries, it also may be problematic, because as
                     employees age they may be more susceptible to injury. In 1994, Springfield
                     did hire about 500 new employees, a large number of whom were women,
                     but they were subsequently laid off throughout 1995. Because these
                     employees were new and perhaps not used to these physical requirements,
                     Springfield suffered increased numbers of injuries while they were on
                     board.


                     The current ergonomics program at Springfield was fully implemented in
Initiating the       1994 with the hiring of the current ergonomist. However, Springfield’s
Ergonomics Program   program has evolved over a decade of experimenting with a number of
at Springfield       different ways to reduce ergonomic hazards and MSDs.

                     Springfield began to implement an ergonomics program as early as 1984,
                     when the UAW required Navistar, in its collective bargaining agreement, to
                     establish a pilot ergonomics program. Navistar corporate officials said
                     there were other influences that contributed to their decision to
                     implement an ergonomics program, including witnessing other employers
                     in the auto industry being cited by OSHA for MSDs, and being encouraged by
                     a consultant who demonstrated ergonomics’ relationship to improved
                     productivity and quality.

                     The pilot ergonomics program was based on local ergonomics committees.
                     Composed of line employees, these committees were tasked with looking
                     for problem jobs and developing controls. However, the employees on
                     these committees often lacked knowledge of ergonomics, lacked the
                     engineering resources necessary to implement suggested controls, and
                     found it difficult to meet because of workload demands. Additionally,
                     Springfield also found there were too many employees on its committee to
                     make it effective. As a result, Navistar and the UAW decided to restructure
                     committee membership so that the only required members would be the
                     local union safety representative and a management safety representative,
                     with other employees brought in as appropriate.

                     In 1991, Springfield decided to hire its first ergonomist to coordinate the
                     ergonomics program. According to the facility manager, most of
                     Springfield’s injuries with lost workdays are caused by ergonomic hazards.
                     However, because the ergonomist reported to the engineering department,



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                        Appendix V
                        The Ergonomics Program at Navistar,
                        Springfield Assembly Facility, Springfield,
                        Ohio




                        competing priorities often meant that ergonomics was not given the same
                        priority as other engineering activities. Springfield subsequently decided to
                        place the ergonomist in the safety department. According to Springfield
                        officials, this organizational change was instrumental in ensuring the
                        ergonomics program received the attention it deserves.


                        Springfield’s ergonomics program is led by a full-time ergonomist and a
Structure and Core      local UAW representative (who works on ergonomics about 3 days a week).
Elements of the         The ergonomist reports to the environmental safety and health manager,
Program at              who reports directly to the facility manager. Other departments are
                        involved with the program, such as the workers’ compensation branch
Springfield             (which tracks workers’ compensation costs), the medical department
                        (which treats injured employees), and the in-house engineering staff
                        (which helps design and implement controls).


Management Commitment   Management commitment to the ergonomics program at Springfield is
                        demonstrated in a number of ways. Springfield has a written document
                        that lays out the various elements of its program, but this is not key to the
                        daily operations of the program. Instead, officials said other, more tangible
                        signs are better indications of management commitment.

                        Springfield has assigned staff—referring to the full-time ergonomist and
                        UAW representative—to manage the program. Specifically, this ergonomics
                        staff is responsible for identifying and analyzing problem jobs, leading
                        efforts to develop controls for those jobs, and overseeing implementation
                        of controls. Additionally, the ergonomist provides training to Springfield
                        employees and develops ergonomic guidelines for them to follow.

                        Navistar has also integrated ergonomic principles into corporate
                        accountability mechanisms. For instance, Springfield is given a cumulative
                        percentage reduction goal for injuries and illnesses. The percentage
                        reduction is based on the number of incidents, the frequency of those
                        incidents, the number of incidents with lost time, and costs for workers’
                        compensation.67 Springfield also uses 5-year strategic business plans that
                        lay out goals and timeframes for completion of those goals. Achieving
                        these goals contributes to compensation decisions affecting managers. For
                        the last 2 years, these strategic plans have included goals for the
                        ergonomics program that have been developed by the ergonomist and the

                        67
                         A daily safety report tracks Springfield’s progress in meeting its overall injury and illness goals. These
                        data are provided to the facility and department managers daily and are posted publicly.



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Appendix V
The Ergonomics Program at Navistar,
Springfield Assembly Facility, Springfield,
Ohio




UAW representative. The most recent plan calls for redesigning processes
ergonomically to reduce injuries and costs associated with MSDs, training
technical support staff on ergonomics, and reducing lost time days and
dollars by bringing employees on workers’ compensation or medical layoff
back to work. Springfield officials said including ergonomic requirements
in the strategic business plan has brought ergonomics to the forefront and
represents a tangible sign of management commitment.

Ergonomic principles have also been incorporated into Navistar’s yearly
safety audits. For the first time, in 1996, Navistar conducted a safety audit
at each of its facilities that scored each facility on various safety matters,
including ergonomics.68 Although the audit was predominantly compliance
based (relating to, for example, record-keeping and maintenance issues), it
also looked for evidence that an effective ergonomics program was in
place—for example, that there was evidence of employee awareness about
ergonomics, that processes were in place to evaluate repetitive trauma
injuries, and that medical staff were involved in the program. The 1996
score will be used as a baseline to evaluate future performance, and
Springfield’s progress relative to this baseline score will be included in
future years’ injury and illness reduction goals. Springfield takes the
results of this audit seriously; as a result of last year’s audit, Springfield
created a management-level ergonomics committee to spread awareness
of the ergonomics program. This committee also helps to ensure
management support for the program. The committee meets bimonthly
and includes representatives from each of the departments of the facility
(primarily department heads or their designees). The committee reviews
the status, feasibility, and appropriateness of various controls that have
been suggested or implemented.

The ergonomics staff also said that suggestions for ergonomic controls
generally have been implemented, although recent budget restrictions
have made it more difficult to justify all types of capital investments.
However, if Springfield does not have the funds to obtain safety-related
items, it can request that corporate Navistar pay for them. Cost
justifications are typically required for ergonomic controls, as they are for
all capital investments. To justify the purchase of the control, the
ergonomist typically cites the costs of injuries or the potential costs of
injuries if the control is not implemented. For example, in a cost
justification for additional automatic lift tables (tables that keep supplies
at an appropriate distance and level for employees by rising as the loads
on them decrease), the ergonomist reported that these tables help to

68
  Safety audits had been performed in prior years, but they had not scored the facilities.



Page 89                                   GAO/HEHS-97-163 Private Sector Ergonomics Programs
                       Appendix V
                       The Ergonomics Program at Navistar,
                       Springfield Assembly Facility, Springfield,
                       Ohio




                       reduce shoulder and back injuries, which have cost the facility well over
                       $200,000 a year in workers’ compensation costs.


Employee Involvement   Navistar relies on committees to accomplish the employee involvement
                       required by the collective bargaining agreement. Springfield’s primary
                       ergonomics committee for identifying problem jobs and developing
                       controls is purposely fluid, based on Navistar’s previous experience with
                       large standing committees during program implementation. The only
                       required members of this committee are the ergonomist and the UAW
                       representative. Other employees (such as the employee doing the job, a
                       line supervisor, an engineer, and the medical director) are pulled in on an
                       ad hoc basis depending upon the particular job being studied and the
                       expertise needed to develop a control. Officials said this type of committee
                       works well because it is relatively small and focused on a particular job, so
                       the analysis and control development can be done fairly quickly.
                       Additionally, corporate officials said this approach allows Springfield to
                       involve a large number of employees in identifying problem jobs and
                       developing controls in a more efficient way than using a standing
                       committee would allow.

                       In some cases, Springfield has formed special committees to address
                       particularly difficult jobs. For example, the “pin job” is considered the
                       most onerous job in the facility. On this job, the frame of the truck is
                       lowered onto the axle. Employees have to “manhandle” the frame so it
                       aligns with the axle, while simultaneously manually hammering in pins
                       that attach the frame to the axle. This job requires significant force,
                       vibration, and awkward postures. Because previously suggested long-term
                       controls for this job would require significant changes in the production
                       process or in the design of the product, Springfield officials said they have
                       recently created a new committee and given it 6 months and an
                       “unlimited” budget to assess the job and develop alternative types of
                       controls.

                       Springfield has also established procedures that allow employees direct
                       access to services. For example, employees can trigger a job analysis
                       simply by submitting a “Request for Ergonomic Study” form to the
                       ergonomist or UAW representative if they feel discomfort or just want to
                       have an analysis performed. This one-page form elicits basic information
                       about the employee involved (name, time of injury, or type of discomfort
                       reported); the “ergonomic concern” being reported (that is, the action that
                       has caused the injury, discomfort, or both); the area of the body affected;



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                            Appendix V
                            The Ergonomics Program at Navistar,
                            Springfield Assembly Facility, Springfield,
                            Ohio




                            and any suggestions the employee may have to alleviate the ergonomic
                            concern. In 1996, the form was revised to also request information on
                            ergonomic risk factors present on the job (repetition, force, awkward
                            postures, vibration, and lifting). Once the ergonomist or UAW
                            representative receives this form, the appropriate employees are convened
                            to conduct a job analysis.


Identification of Problem   Springfield identifies problem jobs primarily on an incidence basis. In
Jobs                        other words, Springfield’s efforts most often are the result of job-related
                            reports of injuries or discomfort to the medical department but can also
                            result from employee requests for job analysis. Springfield has
                            implemented a simple system by which jobs are identified for analysis.
                            Facility officials emphasized that this process must be simple in order to
                            encourage employees to report their injuries or discomfort early. When an
                            employee reports an injury or discomfort to the medical department
                            (Springfield has an on-site occupational health clinic), the medical director
                            evaluates whether the injury or discomfort was caused by an ergonomic
                            hazard, and, if so, completes a Request for Ergonomic Study and gives it to
                            the ergonomist or UAW representative. As noted above, employees or
                            supervisors can also complete this form if they or their employees are
                            feeling discomfort that has not yet resulted in a visit to the medical
                            department or if other conditions exist that lead them to believe there are
                            potential problems with the job. Employees can also informally tell the
                            ergonomist or UAW representative about a problem job during their
                            frequent walk-throughs of the facility without using the form to generate a
                            job analysis.

                            Springfield does not use a discomfort survey to identify potential problem
                            jobs because the results are difficult to interpret, and a survey carried out
                            by an intern several years ago identified those jobs that the ergonomics
                            staff already knew were problematic. Officials said it is difficult to know
                            whether the discomfort being experienced by employees on particular
                            jobs is attributable to the employee’s aging, or whether it is in fact due to a
                            particular job. Even if it could be determined that the job was causing the
                            discomfort, because the nature of jobs changes frequently, it would be
                            difficult to tell whether the discomfort was the result of the job itself or of
                            the interaction between the employee and the job.

                            Although Springfield has spent most of its time on incidence-based
                            identification, the facility has recently started to identify problem jobs on a
                            more proactive basis. The ergonomist asked all supervisors to identify



                            Page 91                              GAO/HEHS-97-163 Private Sector Ergonomics Programs
                          Appendix V
                          The Ergonomics Program at Navistar,
                          Springfield Assembly Facility, Springfield,
                          Ohio




                          problem jobs on the basis of those staffed mostly by employees with low
                          seniority and those with high turnover. In a unionized environment, as
                          employees gain seniority, they can “bid off” of certain less desirable jobs
                          and onto more desirable ones. This means that those jobs done by
                          employees with the lowest level of seniority are probably jobs that most
                          employees do not want to do—and the probable reason for this is that
                          there are ergonomic hazards on these jobs. Officials said using these
                          indicators may be more appropriate than using risk factors. Virtually any
                          job in a manufacturing environment involves risk factors, they said, so it
                          would be prohibitively time consuming and expensive to use risk factors
                          as a basis to identify problem jobs.

                          Although the ergonomist and the UAW representative complete an analysis
                          on every job for which they receive a Request for Ergonomic Study, they
                          currently give the highest priority to those jobs on which injuries have
                          already occurred or discomfort has already been reported to the medical
                          department. The next highest priority is given to those jobs for which a
                          large number of requests for job analysis have been submitted. At this
                          time, the lowest priority is given to those jobs identified by supervisors on
                          the basis of high turnover and low seniority. Aiding in this prioritization is
                          a database developed by the ergonomist called the “Ergonomic Log Line
                          Breakdown,” which tracks all requests for job analysis and provides
                          information such as the employee who was involved, the time the injury
                          occurred or discomfort was reported, the job the employee was working
                          on, and the body part affected.


Analyzing Problem Jobs    Springfield’s process for analyzing jobs and developing controls was
and Developing Controls   described as simple, informal, and purposely not paper intensive. The
                          ergonomist pointed out that a company is less likely to analyze a large
                          number of jobs if there is a lot of paperwork to do for each job analyzed.
                          She said Springfield analyzes about 250 jobs a year, which would not be
                          possible if a lot of paperwork was required. Officials said this process
                          relies heavily on the in-house resources at the facility, such as the
                          employees doing the job and facilities engineering staff. In some cases, a
                          detailed analysis is done if the job is particularly complex.

                          The ergonomics staff stressed that the process must be continuous, as it is
                          not always feasible to correct all hazards on every job, especially the first
                          time out. While some effort is always made to alleviate at least some of the
                          hazards on the job, the process must ensure that the problem job is
                          revisited as long as the problem continues to exist. Officials also said that



                          Page 92                              GAO/HEHS-97-163 Private Sector Ergonomics Programs
                               Appendix V
                               The Ergonomics Program at Navistar,
                               Springfield Assembly Facility, Springfield,
                               Ohio




                               most of the controls that have been implemented have been administrative
                               or “low-tech” engineering controls. For a description of controls
                               developed to eliminate ergonomic hazards associated with windshield
                               installation, see appendix II.

Process Used to Analyze Jobs   To analyze a job, the ergonomist or the UAW representative assembles a
                               committee of individuals and watches an employee perform the job in
                               question to get a good understanding of the job requirements and what
                               may be causing the problem. In some cases, the analysis is based on the
                               information already provided on the Request for Ergonomic Study form.
                               Typically, the analysis does not involve breaking the job down into
                               component parts, although the committee often studies problem areas,
                               which are generally the “ergonomic concern” stated on the Request for
                               Ergonomic Study form, such as lifting or reaching.

                               If necessary, a more detailed analysis is conducted. Jobs are not
                               videotaped, because that would violate provisions of the bargaining
                               agreement, but if the job is particularly complex, the analysis process is
                               lengthy, or a large number of people are involved, Springfield may use an
                               additional form called the “Ergonomic Assessment Form.” This two-page
                               form elicits additional information, such as the type of work being done
                               (for example, hand-intensive and manual materials handling), the risk
                               factors present, and the tools and parts used. This form is used by a sister
                               facility for all of its job analyses; however, according to the Springfield
                               ergonomist, it is not reasonable for Springfield to use this form because of
                               the number of jobs analyzed each year.

Process Used to Develop        Once the committee has finished analyzing the job, it follows an informal
Controls                       process to develop controls. The officials told us no specific tools are used
                               to develop controls. Instead, the process is fluid and varies depending
                               upon the problem itself. In some cases, the employee, supervisor, or
                               whoever submitted the Request for Ergonomic Study has already
                               suggested a control based on his knowledge of the job. In other cases, the
                               committee identifies other operations in the facility to determine whether
                               their controls may be appropriate for this job. The officials said it is
                               imperative that they “walk the floor” to understand what the jobs are and
                               what types of controls may be effective. For example, for the cab part of
                               the truck to be adequately attached to the frame, the cab must be
                               positioned at a particular angle. To accomplish this, employees previously
                               had to “jack up” the cab with a car-type jack numerous times a day and
                               were experiencing back, shoulder, and other problems as a result. The UAW
                               representative knew that employees on other production lines were using



                               Page 93                              GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix V
The Ergonomics Program at Navistar,
Springfield Assembly Facility, Springfield,
Ohio




a hydraulic pump to lift up the cab and suggested to the employees
working on this process that they look into whether this type of control
would work. These employees are now using a hydraulic pump, and
discomfort has been reduced.

For more complex situations, the committee presents the problem to the
in-house engineers and asks them to develop controls. For example, on the
radiator line, employees had to attach a metal casing (called a “horse
collar”) to the radiator, which was suspended from an overhead line.
Because the holes on the casing and the radiator were not lining up
properly, employees had to manually pry the components with a
screwdriver to adjust the holes before inserting the bolts. A number of
employees were complaining of fatigue and pain from this job, and there
were quality problems because the bolts were sometimes inserted
incorrectly. In this case, the in-house engineers designed a U-shaped
“spreader bar” that precisely aligns the holes in the radiator with those in
the casing. The spreader bar has eliminated the physical strain of the
employees and also improved the quality of the work.

Springfield officials said they used no specific threshold to determine
whether and when a control should be put in place. In most cases, these
are judgment calls based on several factors, such as the severity of the
problem or hazard, the extent to which the problem can be fixed, and the
time or resources needed to develop and implement controls. Because of
the limited number of in-house engineers to design or implement controls,
Springfield tries to prioritize controls on the basis of likely injuries and
other costs if the job is not fixed.

Facility officials acknowledged that the program is never completed and
the ergonomics staff is always on the lookout for improving existing
controls. However, follow-up is typically informal, as there are insufficient
time and resources to formally follow up on all jobs where controls have
been implemented. However, the Ergonomic Log Line Breakdown can
help the ergonomist determine whether jobs that have been analyzed
continue to be the subject of requests for ergonomic study. If they are, the
ergonomics staff will continue to revisit those jobs.

The iterative nature of the program is especially important because not
every hazard on every job can be totally eliminated. Facility officials said a
small number of jobs they have analyzed have not been able to be fixed,
primarily because it would have been prohibitively expensive to do so,
requiring a change in product or in the production process. However, even



Page 94                              GAO/HEHS-97-163 Private Sector Ergonomics Programs
                                Appendix V
                                The Ergonomics Program at Navistar,
                                Springfield Assembly Facility, Springfield,
                                Ohio




                                in these cases, as with the pin job, Springfield has made repeated efforts to
                                reduce exposure to hazards through other means. The establishment of
                                the committee to develop controls for the pin job is the most recent
                                example of this iterative process.

                                In some cases, it is difficult to implement controls immediately because of
                                the complexity of the product, the customization of the product, or the
                                facility layout. In these cases, changes must often be implemented when a
                                production or schedule change takes place. This was the case with the
                                change in how windshields are installed (see app. II). On the other hand,
                                constantly making changes can make it difficult to know whether controls
                                are working. Additionally, it is not always feasible or appropriate to take a
                                control implemented on one job or workstation and implement it on all
                                similar jobs or workstations. For example, Springfield currently has about
                                30,000 guns at the facility that are used to drill in bolts. Many of these guns
                                are “impact” guns that have excessive vibration, but they are very
                                powerful. As many of the impact guns wear out, Springfield is replacing
                                them with “nutrunner” guns, which are less powerful but cause less
                                vibration. Facility officials said it is not reasonable or feasible to expect
                                Springfield to replace every impact gun immediately; moreover, in some
                                cases, nutrunner guns are not an acceptable replacement for impact guns.

Types of Controls Implemented   Springfield has implemented a mix of controls, focusing on the most
                                cost-effective controls in their efforts to at least partially address identified
                                hazards on every job analyzed. The ergonomist estimates that only about
                                10 percent of the controls implemented have been engineering controls,
                                and most of these have been considered “low tech,” because they have not
                                been extremely costly or significantly changed the job. For example,
                                Springfield has installed hoists to lift 120-pound fuel tanks and mechanical
                                articulating arms to transport carburetors down an assembly line. These
                                controls have eliminated the manual lifting and strain associated with
                                handling these heavy objects. The facility has also installed automatic lift
                                tables, which rise as the load lessens, to reduce reaching and bending by
                                employees and has improved hand tools used to do the jobs. Springfield’s
                                program also covers employees who work in an office environment.
                                There, Springfield has provided ergonomic chairs, filters for computer
                                screens, and articulating keyboard trays.

                                Most of the controls Springfield has implemented are administrative
                                controls or personal protective equipment. Administrative controls have
                                included training for office employees and a guideline for engineers to use
                                when designing products. Padded gloves, elbow supports, and other



                                Page 95                              GAO/HEHS-97-163 Private Sector Ergonomics Programs
                         Appendix V
                         The Ergonomics Program at Navistar,
                         Springfield Assembly Facility, Springfield,
                         Ohio




                         protective equipment are commonly used throughout the facility,
                         especially in those cases, such as the pin job, where it has been difficult to
                         address hazards through engineering controls.


Training and Education   To date, Springfield has not provided basic awareness training to
                         employees but has instead provided general information about ergonomics
                         informally through posters, word of mouth, and pamphlets. While
                         Springfield would like to provide awareness training to all new employees
                         and employees working on the production floor, there has been some
                         difficulty taking employees off the floor during work hours for training.

                         Springfield has focused on providing targeted training to office employees
                         and production supervisors. For example, the ergonomist provided
                         training to office employees to help them understand how to arrange their
                         workstations to be more comfortable. In 1997, the ergonomist began to
                         teach a technical training class for supervisors and engineers. This class
                         provides 4 hours of basic information on MSDs, as well as up to 4 hours of
                         additional information for material handling analysts, supervisors, and all
                         engineers.


Medical Management       Springfield’s program has established strong linkages with its medical
                         management staff to ensure early reporting and prompt evaluation.
                         Springfield has a fully equipped on-site occupational health clinic that is
                         able to treat most of the injuries experienced by Springfield employees,
                         with rare referrals to local health care providers. The medical director told
                         us that having a clinic on site means that employees are less likely to leave
                         work for medical attention and that she is more involved with and aware
                         of what the employees are doing, how the injury or discomfort occurred,
                         and how similar problems can be avoided in the future. Other officials said
                         having an in-house doctor and medical staff helps Navistar, which is
                         self-insured, keep medical costs down.

                         The medical director is closely linked with the ergonomics program in
                         several ways. Primarily, she can request a job analysis (through the
                         Request for Ergonomic Study form) when an employee reports to the
                         medical department discomfort or an injury that she believes was due to
                         an ergonomic hazard. In fact, the recent change to this form to identify
                         risk factors was initiated at the request of the medical director. Also, in
                         many cases, the medical director participates on the ad hoc ergonomics
                         committee, as well as on the management-level ergonomics committee,



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                         Appendix V
                         The Ergonomics Program at Navistar,
                         Springfield Assembly Facility, Springfield,
                         Ohio




                         and helps analyze and develop controls for problem jobs. Additionally,
                         when there are questions about the premise of a workers’ compensation
                         claim, the medical director calls together the ergonomist and a
                         representative from the workers’ compensation branch to discuss the
                         validity of the claim. This workers’ compensation causation committee
                         also helps to identify causes of injuries.

                         Springfield also uses restricted- and transitional-duty assignments in an
                         effort to return injured employees to work. The medical director said this
                         is key to a successful, cost-effective program. However, Springfield faces
                         several challenges in this regard. For example, if an injured employee has
                         been given a particular work restriction, the available job that
                         accommodates that restriction may not be available to the employee
                         because he or she does not have enough seniority to work on that job. In
                         other cases, some of the jobs available to injured employees, such as
                         sweeping, are not seen as being productive, so employees are reluctant to
                         take these jobs.


                         Navistar officials said they are generally satisfied with Springfield’s
Results and Issues       ergonomics program’s contribution to improved worker safety and health,
Related to Program       reduced injury rates, and lower workers’ compensation costs. Officials
Performance              said they use a number of measures to look for results of the ergonomics
                         program, since it is inappropriate to consider just one measure and
                         exclude others. However, officials raised a number of issues that need to
                         be considered when reviewing these results and that often complicate
                         their ability to tie results directly to their efforts.


Reductions in Workers’   As shown in figure V.1, Springfield reduced its costs for workers’
Compensation Costs       compensation claims associated with MSDs69 from almost $1.4 million in
Associated With MSDs     199370 to $544,000 in 1996—a decline of over 60 percent. Additionally,
                         during this same period, the average cost for each claim declined almost
                         by half, from $9,500 in 1993 to $4,900 in 1996 (see fig. 3), which provides
                         some evidence that the facility has been encouraging early reporting and


                         69
                           To capture MSDs, Springfield tracks the following injury categories: “repetitive trauma,” “carpal
                         tunnel syndrome,” “thoracic outlet syndrome,” “tendinitis,” “epicondylitis,” “torn rotator cuff,” “torn
                         meniscus,” and “acute strains involving the back.”
                         70
                          As discussed in app. I, the years of data provided for each facility differ depending upon when facility
                         officials believe the current program was fully implemented. In most cases, we present data from the
                         year prior to full implementation of the program through 1996 in order to show changes that occurred
                         at the facility during the years of the ergonomics program’s operation. For Springfield, since the
                         current program was fully implemented in 1994, we present data beginning in 1993.



                         Page 97                                   GAO/HEHS-97-163 Private Sector Ergonomics Programs
                                           Appendix V
                                           The Ergonomics Program at Navistar,
                                           Springfield Assembly Facility, Springfield,
                                           Ohio




                                           providing early treatment. According to data provided by the ergonomist,
                                           Springfield also avoided about $250,000 in workers’ compensation costs
                                           between 1994 and 1996 as a result of reductions in carpal tunnel
                                           syndrome, repetitive trauma, and back injuries.

                                           During this same period, total costs for workers’ compensation declined
                                           by about 15 percent. But the facility did not achieve its overall safety
                                           percentage reduction goal in 1996 because of several large claims and the
                                           difficulty it experienced in returning injured employees to work.


Figure V.1: Workers’ Compensation
Costs for MSDs at the Navistar Facility,   1500   Total Dollars for MSD Claims (in Thousands)
1993-96                                           1390




                                           1000

                                                             805
                                                                      762



                                                                                544
                                            500




                                              0

                                                     1993     1994     1995      1996
                                                     Calendar Year



                                           Source: Navistar’s workers’ compensation database.




                                           Navistar officials said several factors need to be considered when looking
                                           at their experience with workers’ compensation costs. First, there is
                                           uncertainty about what injuries should be considered MSDs. The
                                           ergonomist preferred to track injury categories directly tied to identifiable
                                           ergonomic hazards, such as lifting or repetition. On the other hand,
                                           corporate officials preferred to track all injuries to which ergonomic
                                           hazards may contribute.




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                             Appendix V
                             The Ergonomics Program at Navistar,
                             Springfield Assembly Facility, Springfield,
                             Ohio




                             Officials also said that hiring 500 new employees in 1994 and laying them
                             off shortly thereafter contributed to increases in injuries, claims, and
                             associated costs. New, inexperienced employees are more likely to
                             become injured, and claims also tend to increase before a layoff because,
                             if an employee can qualify for a medical restriction, he or she will be able
                             to receive workers’ compensation during a layoff. When the layoff ends,
                             claims generally decrease. In 1995, Navistar did experience an increase in
                             total workers’ compensation claims, although this spike did not appear in
                             costs associated with MSD claims.


Reductions in Injuries and   Navistar also uses the OSHA 200 log to assess its performance in reducing
Illnesses According to the   injuries and illnesses on a facilitywide basis. Additionally, these data are
OSHA 200 Log                 used by OSHA in its inspection activities. According to these data for 1993
                             through 1996, Springfield reduced the number of injuries and illnesses for
                             every 100 employees (referred to as the incidence rate) from 20.3 in 1993
                             to 14.2 in 1996 (see fig. 4). Additionally, in 1995, Springfield’s incidence
                             rate of 16.1 was significantly lower than the industry average of 22.5, based
                             on the most recent available data, for other assemblers of truck and bus
                             bodies. Springfield also reduced the number of lost and restricted days for
                             every 100 employees by 122 days and 35 days, respectively (see fig. 2).

                             However, the ergonomics staff at Springfield said these data are not
                             helpful for identifying or tracking reductions in MSDs. They said the OSHA
                             log does not provide enough information to enable them to fully
                             understand the circumstances surrounding an injury, or how it should be
                             recorded. Officials also said injuries such as back injuries are recorded as
                             acute, rather than as repetitive trauma, while in a manufacturing
                             environment, most back injuries are the result of repeated lifting.


Improvements in              Officials believed that, in many cases, ergonomic improvements had
Productivity, Quality, and   contributed to productivity, quality, and morale improvements. While the
Morale                       facility is not formally tracking productivity or quality improvements
                             resulting from the program, the facility manager said the relationship
                             between ergonomics and improving quality and performance cannot be
                             denied. Additionally, the ergonomist reported that those departments with
                             the most quality problems also tend to have the lowest seniority and most
                             ergonomic problems. Officials cited examples, such as the redesign of the
                             windshield installation process as discussed in appendix II, in which
                             Navistar has been able to achieve quality as well as ergonomic
                             improvements.



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Appendix V
The Ergonomics Program at Navistar,
Springfield Assembly Facility, Springfield,
Ohio




However, corporate officials said it is difficult to distinguish the benefits
gained by “ergonomic” investments from those resulting from efforts to
increase productivity or reduce rework. Concerns were also raised that, in
some cases, ergonomic controls may actually decrease productivity—for
instance, when additional employees are assigned to do the same amount
of work that one employee had been doing.




Page 100                             GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix VI

The Ergonomics Program at SOCHS,
Lewiston, Maine

              The Sisters of Charity Health System is a for-profit health care provider
Background    located in Lewiston, Maine. It includes a not-for-profit 233-bed
              acute/behavioral medical care facility (St. Mary’s Regional Medical Center)
              and a not-for-profit 280-bed long-term-care nursing facility (St. Marguerite
              d’Youville Pavilion).71 These two entities employ about half of SOCHS’
              workforce of 1,400 nonunion employees—522 employees work at the
              medical center and 253 work at the nursing home.

              A number of local conditions set the stage for the implementation of the
              ergonomics program at the medical center and nursing home. In 1993, to
              prepare for managed care, SOCHS began to streamline management
              structures, improve client relations, and gain a better handle on costs by
              becoming self-insured.72 As a result, when OSHA invited the medical center
              and nursing home to participate in the Maine 200 program,73 SOCHS agreed.
              SOCHS realized the ultimate goal of the program—to reduce injuries and
              illnesses through establishing a safety and health program—supported
              SOCHS’ efforts to reduce costs and increase efficiency. OSHA’s offer to
              provide assistance and the good relationship SOCHS had with OSHA were
              also factors in the decision.

              SOCHS  had been aware of its high workers’ compensation costs because,
              when it became self-insured, it was required by the Bureau of Insurance to
              set aside considerable funds to develop a trust to cover future workers’
              compensation claims (the amount was based on historical claim
              experience). Additionally, SOCHS knew that a leading cause of lost time was
              back injuries of CNAs who did most of the patient handling at the nursing
              home. Also, employees working in the laboratory, medical records,
              registration, and other heavily computer- and phone-intensive operations
              at the medical center were suffering various hand and wrist injuries. The
              offer from OSHA provided additional incentive for SOCHS to address these
              injuries.




              71
                SOCHS also has an independent living facility, community clinical services, and a food service
              facility.
              72
                This decision was also a reaction to the workers’ compensation crisis Maine was experiencing at the
              time. Insurers were leaving the state, and employers were leaving because they were unable to find an
              insurer.
              73
                Under this program, OSHA targeted employers with high numbers of workers’ compensation claims
              with lost workdays for 1991. OSHA offered employers the choice of working with it to reduce those
              injuries or being subject to an on-site inspection.



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                     Appendix VI
                     The Ergonomics Program at SOCHS,
                     Lewiston, Maine




                     Officials told us the program was fully implemented in 1994 after they had
Initiating the       undertaken a number of efforts in response to OSHA’s September 1993
Ergonomics Program   invitation to participate in the Maine 200 program. These efforts were
at SOCHS             generated by the requirements to participate in the program. To
                     participate, the medical center and nursing home had to conduct a
                     baseline hazard survey to identify existing hazards, set up an action plan
                     that outlined the steps the facility would take to address identified
                     hazards, and establish a comprehensive safety and health program that
                     would seek to reduce injuries and the contributing hazards. The facilities
                     were also required to report quarterly to OSHA on their progress and allow
                     OSHA inspectors to conduct on-site monitoring visits. Along with its
                     invitation, OSHA also provided SOCHS its Safety and Health Program
                     Management Guidelines, which were to be the framework for SOCHS’ safety
                     and health program.

                     The first thing SOCHS did was contact a consultant who said that staff
                     should be assigned to manage the program. Soon after, SOCHS hired a
                     safety coordinator to establish a safety and health program. The
                     consultant also suggested setting up a system to track injuries and
                     workers’ compensation costs. Because existing systems were inadequate,
                     SOCHS hired a risk management coordinator to develop a database to track
                     the number and type of employee injuries, the number of lost and
                     restricted workdays, and related information. A second system was
                     developed in conjunction with the third-party administrator to track costs
                     of claims.

                     The safety coordinator conducted the required baseline hazard survey. On
                     the basis of the survey results, SOCHS developed action plans that laid out
                     how the medical center and nursing home would address the identified
                     hazards and injuries. SOCHS also began to establish procedures to
                     implement the elements of an effective safety and health program.


                     SOCHS’  ergonomics program is led by several officials located in the human
Structure and Core   resources department—the director of risk management and safety, the
Elements of the      safety coordinator, and the risk management coordinator. A doctor and an
Program at SOCHS     ergonomist/nurse with the on-site occupational health clinic (called
                     WorkMed) dedicate most of their time to conducting workstation
                     evaluations, helping to develop controls, and treating injured employees.
                     Other in-house resources, such as engineering staff, also work with these
                     staff to develop controls.




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                        Appendix VI
                        The Ergonomics Program at SOCHS,
                        Lewiston, Maine




                        Officials said that when MSDs constitute the majority of injuries and
                        illnesses, they are a priority under SOCHS’ safety and health program. When
                        other injuries (such as slips and falls on icy parking lots or injuries from
                        combative patients) constitute a majority of the injuries, then they are a
                        priority.


Management Commitment   Management commitment to the ergonomics program at SOCHS is
                        demonstrated in a number of ways. SOCHS does not have a formal
                        ergonomics document for either the medical center or the nursing home,
                        but officials told us the quarterly reports to OSHA that chart the facilities’
                        progress in meeting goals and information provided in meetings and
                        training for senior management and supervisors are the best indicators of
                        the daily operations of the program.

                        SOCHS  officials said there must be a point person responsible for making
                        sure things get done and that person must have the resources to deal with
                        problems. Because of this view, SOCHS has assigned staff to be responsible
                        for the program. Key are the director of risk management and safety, the
                        safety coordinator, and the risk management coordinator. These
                        employees are responsible for addressing hazards, providing training, and
                        tracking injuries and costs.

                        Additionally, SOCHS has integrated ergonomic principles into the purchase
                        and design of equipment. For example, WorkMed must certify that all new
                        office construction incorporates ergonomic furniture and design.
                        WorkMed has helped design new office space in the medical records
                        department and the emergency registration area at the medical center, as
                        well as in other areas. Additionally, the nursing home recently bought new
                        medical carts to eliminate identified ergonomic hazards. Medical carts are
                        used to store residents’ medications and are wheeled around the nursing
                        home when medications are dispersed. Several shorter employees had
                        suffered wrist injuries resulting from having to reach into awkward
                        positions to get the medications. Because the ergonomics staff notified the
                        nursing home administration about this hazard, the nursing home looked
                        for and purchased shorter carts that had side drawers that could hold
                        medications and accommodate these shorter employees.

                        SOCHS has also made financial resources available to the program. For
                        example, early on, SOCHS spent $60,000 on 14 automatic lifts for the nursing
                        home and has since purchased another as a “spare.” Officials said making
                        such a significant investment early in the program required a “leap of faith”



                        Page 103                           GAO/HEHS-97-163 Private Sector Ergonomics Programs
                       Appendix VI
                       The Ergonomics Program at SOCHS,
                       Lewiston, Maine




                       that it would pay off, because there were no real data to support such an
                       investment. Ergonomics staff noted, however, that this investment needs
                       to be considered in light of the cost of just one back injury, which could
                       cost more than $60,000. Additionally, officials said suggestions for
                       ergonomic controls are typically implemented; in fact, in 1997, the director
                       of risk management and safety was given additional funding for ergonomic
                       controls that were not accounted for in departmental budgets.

                       SOCHS has also ensured management support for the program in several
                       ways. For example, if managers do not address identified hazards and
                       employee complaints promptly, the safety coordinator has the authority to
                       take action against these managers.


Employee Involvement   SOCHS relies on a number of committees to identify hazards, including
                       ergonomic hazards.74 These committees do not identify problem jobs or
                       develop controls; instead, according to SOCHS management, these
                       committees work to provide a heightened awareness of safety and
                       ergonomic principles throughout SOCHS by keeping an eye on overall
                       workplace conditions and notifying the ergonomics staff when they see
                       items that need to be addressed. The committees meet once a month
                       during work hours and draw membership from hourly as well as
                       managerial employees and, in some cases, doctors. Management reviews
                       the minutes from these committee meetings.

                       Recently, an ergonomics task force was formed.75 The task force has about
                       nine volunteer employees, and the safety coordinator, the director of risk
                       management and safety, doctors, and officials from purchasing and
                       engineering provide guidance to the task force. The ultimate goals of the
                       task force are to help develop priorities for hazards that need to be
                       addressed and to help employees address those hazards that may not be
                       serious enough to merit a workstation evaluation by WorkMed.

                       SOCHS has also established procedures that provide employees direct
                       access to services. For example, if employees want a workstation
                       evaluation, they can simply call WorkMed to request one. Officials also
                       emphasized the value of employee input during these evaluations and said
                       many of the controls come from employees.

                       74
                         The medical center and the nursing home each has its own safety committee. Subcommittees of
                       these safety committees address specific hazards, such as needlesticks or combative patients.
                       75
                        This task force is actually a subcommittee of the medical center safety committee, but employees
                       who work at the nursing home are also members.



                       Page 104                                GAO/HEHS-97-163 Private Sector Ergonomics Programs
                            Appendix VI
                            The Ergonomics Program at SOCHS,
                            Lewiston, Maine




Identification of Problem   SOCHS identifies problem jobs primarily on an incidence basis. In other
Jobs                        words, most of SOCHS’ efforts result from a report of injury or discomfort
                            or from employee requests for assistance because of other reasons.76

                            SOCHS  has established a simple system by which problem jobs are
                            identified. If an “incident” occurs (at SOCHS this means an injury or feeling
                            of discomfort), the employee and supervisor are required to complete
                            separate “Report of Employee Incident” forms within 24 hours.77 The
                            employee’s form elicits information about the employee involved (such as,
                            age, sex, and position); the incident (location, time, date, witnesses,
                            explanation of what the employee was doing at the time of the incident,
                            and the body part affected); and steps taken after the incident occurred
                            (whether first aid was provided or referral to WorkMed was made). The
                            supervisor’s form elicits information about the length of time the employee
                            has been doing this task or job, what may have contributed to the incident,
                            corrective actions the supervisor has taken for the affected employee
                            (which must be taken within 72 hours), and actions the supervisor is
                            taking to prevent a similar incident in the future. This form is then
                            forwarded to WorkMed, which performs a physical examination of the
                            employee. After the examination, WorkMed determines whether the injury
                            or reported discomfort is due to ergonomic hazards (such as experiencing
                            shoulder pain from prolonged use of microscopes) and, if so, WorkMed
                            performs a workstation evaluation.78 Workstation evaluations can also be
                            triggered simply by a phone call to WorkMed if the employee does not
                            need a physical examination.

                            Although SOCHS devotes most of its time to workstation evaluations
                            resulting from complaints of discomfort or employee requests for
                            assistance, SOCHS also identifies problem jobs on the basis of potential
                            risks. For example, when an employee relocates or changes jobs,
                            WorkMed is required to conduct a workstation evaluation to ensure that
                            the employee’s new workstation is set up correctly and that the employee
                            is aware of potential hazards on his or her new job. Additionally, when
                            entire departments are relocating or when new construction is taking

                            76
                             SOCHS’ baseline survey required by Maine 200 participation did not identify a significant number of
                            ergonomic hazards.
                            77
                             This form is also filled out if there is a “near miss”—that is, when an incident has not occurred but
                            might have. In such cases, the safety coordinator determines whether an evaluation or job analysis is
                            necessary.
                            78
                              If WorkMed decides the injury has occurred because employees were not following safety guidelines
                            (for example, a CNA suffers a back injury as a result of not using automatic lifts to transfer residents)
                            or because of other factors (a fall due to an icy parking lot), WorkMed refers the matter to the safety
                            coordinator on the assumption that it can be addressed without a workstation evaluation.



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                               Appendix VI
                               The Ergonomics Program at SOCHS,
                               Lewiston, Maine




                               place, WorkMed provides guidance on appropriate workstation and
                               equipment design and must certify that design is ergonomic before final
                               approval.


Analyzing Problem Jobs         SOCHS   officials said the process it uses to analyze problem jobs is simple. In
and Developing Controls        fact, it stressed that, in most cases, it conducts workstation
                               evaluations—making physical changes to an individual’s workstation to
                               make the job more efficient and the employee more comfortable—rather
                               than job analyses—evaluating whether tasks of a job or operation should
                               be changed. Although there have been times where SOCHS has done job
                               analyses, officials said it is not always practical or necessary to conduct a
                               detailed job analysis in order to reduce hazards. The safety coordinator
                               said that if a job was causing problems for more than one employee, he
                               might undertake a job analysis to break down the job into tasks and make
                               recommendations to change some of those tasks. However, he has not
                               done this recently, because he can often make changes without having to
                               do such detailed analysis.

                               SOCHS officials described their process for developing controls for problem
                               jobs as informal. They emphasized the importance of using in-house
                               resources to develop controls because employees know the job process
                               and often can provide the best information on how the workstation can be
                               improved. The officials also noted that the process is a continuous one.
                               There is no specific threshold for when and whether a control should be
                               implemented, and something can always be done to reduce a hazard or
                               respond to the cause of the injury. Officials said a large number of the
                               controls that have been implemented have concerned better work
                               practices, while others have been “low-tech” engineering controls that
                               have not drastically changed the job or operation.

Process Used to Analyze Jobs   When WorkMed officials conduct evaluations,79 they spend about an hour
                               watching the employees perform the job and taking physical
                               measurements of the current workstation design (desk height, monitor
                               placement, and chair height) and the employee as he or she relates to the
                               workstation (appropriate elbow height when seated, for example).
                               WorkMed may also assess the general workplace conditions, such as light
                               and noise levels, but it does not follow a particular format for these
                               evaluations. Because WorkMed is not technically a component of SOCHS, it



                               79
                                 On a few occasions, workstation evaluations have been performed by a private consultant because
                               there was some question about the validity of the results of the evaluations WorkMed had done.



                               Page 106                               GAO/HEHS-97-163 Private Sector Ergonomics Programs
                          Appendix VI
                          The Ergonomics Program at SOCHS,
                          Lewiston, Maine




                          charges SOCHS for these evaluations. Since 1995, SOCHS has spent about
                          $10,000 for evaluations at the nursing home and the medical center.

                          Although SOCHS does not typically videotape jobs, it may perform detailed
                          analyses of jobs. For example, in the surgical area at the medical center,
                          one job requires a secretary to input a significant number of medical
                          charges into a computer. This is an extremely stressful job, because if
                          items are omitted or input incorrectly, the medical center loses revenue.
                          The secretary is required to perform several other tasks simultaneously,
                          which contributes to the overall difficulty of the job. In doing its analysis
                          of this job, SOCHS evaluated not only the physical characteristics of the
                          workstation (work surface and chair height), but also the environment
                          (noise and other distracting influences) and the numerous additional
                          required tasks to determine whether any of these tasks could be
                          eliminated or altered to reduce the stress of the position and increase the
                          efficiency of the data input process.

Process Used to Develop   Once the WorkMed staff have completed the workstation evaluation, they
Controls                  work with the employee who performs the job, in-house engineering staff,
                          or others to “brainstorm” possible suggestions for eliminating the
                          identified hazard. Officials said that often the employees themselves have
                          suggestions for what controls to make. WorkMed officials said that when
                          developing controls, they try to do those things that are easy to
                          accomplish or fairly inexpensive. Additionally, for the duration of its
                          participation in the Maine 200, SOCHS obtained ideas for controls from the
                          compliance officer who had been assigned to it. Because of her familiarity
                          with SOCHS and because she also had been assigned to similar employers in
                          the health care industry, she was able to suggest ideas for controls that
                          had worked for other employers.

                          WorkMed incorporates these suggestions into its evaluation summary—a
                          two- to three-page memorandum that is provided to the director of risk
                          management and the employee’s supervisor. The director of risk
                          management evaluates the suggestions; determines how much
                          implementing them will cost; and forwards them, along with their costs, to
                          the cognizant department head for review and approval. For example,
                          WorkMed recently suggested controls to alleviate employee discomfort in
                          the shoulders and neck from excessive phone use, and back and arm
                          discomfort from inappropriate computer workstation design in the
                          medical center’s reception area. WorkMed suggested buying headsets for
                          the employees; putting monitors on articulating risers so they could be
                          placed at appropriate heights for numerous users; and buying ergonomic



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                                Appendix VI
                                The Ergonomics Program at SOCHS,
                                Lewiston, Maine




                                chairs, among other suggested controls. These controls will cost about
                                $4,000.

                                In many cases, controls have been developed by in-house engineering
                                staff. For example, an in-house engineer created an adjustable, slanted
                                wooden surface that can be used as a mouse pad. A patent is currently
                                pending on this item. In another instance, in-house engineers designed a
                                wood computer monitor riser that elevates monitors to the appropriate
                                height.

                                Facility officials agreed that analyzing problem jobs and developing
                                controls must be a long-term effort, and the key is to look for continuous
                                improvement. Accordingly, WorkMed or the ergonomics staff follows up
                                after a workstation evaluation is performed if problems persist.

                                Officials also mentioned that not all problems can be fixed immediately,
                                since the ability to implement controls is often dependent upon available
                                resources. For example, the ideal way to adequately address the hazards
                                on the surgical secretary job mentioned above would be to implement a
                                computer system that would allow employees to input the medical charges
                                as they are accrued, thereby reducing the amount of keying required by
                                the secretary. However, this type of computer system could cost over
                                $200,000. Until the facility is able to afford this control or comes up with
                                another alternative, SOCHS is trying other methods, such as rotating
                                workers through the position on a part-time basis, in order to relieve the
                                pressure of this job.

Types of Controls Implemented   SOCHS has implemented a mix of controls equally distributed between
                                engineering controls (such as buying equipment), which alleviate or
                                reduce hazards, and administrative controls, which encourage proper
                                work techniques. Officials said that most of both types of controls have
                                been inexpensive.

                                Perhaps the single greatest identifiable investment made by SOCHS on
                                engineering controls has been for automatic lifts for the nursing home,
                                which cost about $60,000 (see the detailed discussion about these lifts in
                                app. II). SOCHS has instituted a variety of other types of engineering
                                controls in the laboratory area at the medical center. Employees who
                                work in this area use computers, phones, and microscopes extensively.
                                Because of the former configuration of lab counters and chairs, employees
                                often had to use awkward postures to input data or use the microscopes.
                                As a result, employees were experiencing shoulder, neck, and hand



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                         Appendix VI
                         The Ergonomics Program at SOCHS,
                         Lewiston, Maine




                         discomfort, as well as some injuries. SOCHS lowered the countertops,
                         bought adjustable ergonomic chairs, placed the monitors on articulating
                         monitor risers to accommodate multiple users, raised the microscopes,
                         and put glare screens on the computers. In the laundry room area, SOCHS
                         has also placed false bottoms in laundry bins that rise as the load becomes
                         lighter so employee bending and reaching are minimized.

                         SOCHS  has also used administrative controls. For example, smaller laundry
                         bags that hold only a limited amount of laundry are now used so
                         employees’ lifting requirements are lessened. SOCHS has also purchased
                         antifatigue mats for its employees who stand while working. SOCHS has
                         also offered body mechanics training and increased staffing to better
                         manage high workloads in some work areas. WorkMed officials
                         emphasized that quite often controls involve telling employees how to use
                         better work practices. For example, recently a laboratory employee was
                         experiencing a great deal of wrist pain resulting from the practice of
                         dropping liquid from an eyedropper into a test tube. After watching the
                         employee perform the job, it was found that she was flicking her wrist
                         back after she dropped the liquid in the test tube. In this case, the control
                         was a recommendation that she not flick her wrist. In the medical center’s
                         medical records area, employees were also experiencing wrist and hand
                         pain from shoving copies of patient records onto shelves. In response,
                         SOCHS instituted work policies that employees are supposed to follow for
                         handling these records: They are supposed to leave space between each of
                         the records to avoid using a pinch grip to pull out or push in the records.


Training and Education   SOCHS has provided general ergonomics training as a part of mandatory
                         safety training. The class is offered twice a month for 4-1/2 hours at a time,
                         about 3 hours of which focus on body mechanics (for example, correct
                         positioning for various activities, such as lifting) and proper use of video
                         display terminals. If employees do not attend this training, they will not
                         receive their performance ratings.80 SOCHS officials said this training is
                         required by several OSHA standards, Maine’s accreditation committee for
                         health care organizations,81 and a state law that requires training for
                         employees who work in front of video display terminals for at least 4
                         hours a day. Other general awareness education for ergonomics has been
                         provided through an employee newsletter and advice from a “safety
                         mascot.”

                         80
                           With the exception of new employees, employees can take a test that allows them to opt out of this
                         training for 1 year.
                         81
                           Health care organizations must be licensed by this committee to operate in Maine.



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                     Appendix VI
                     The Ergonomics Program at SOCHS,
                     Lewiston, Maine




                     The officials said that it is not feasible to require employees to attend
                     training for more than 4 hours at a time or more than once a year. In the
                     past, they said, they were unable to get people to stay in training when it
                     was longer. Additionally, so much training is already required for health
                     care organizations that any additional training must be reasonable and
                     directly related to employees’ tasks.

                     Given these concerns, SOCHS provides specialized ergonomics training for
                     employees on the basis of the risks they are exposed to and their job
                     requirements. For example, newly hired CNAs and other staff are given
                     training on how to use the automatic lifts. The ergonomics committee
                     leaders have also received training on how to identify and prioritize
                     hazards. SOCHS also provides back training to all new employees working
                     in areas where a significant amount of lifting takes place. For the last 4
                     years, supervisors have also received training on the procedures they must
                     follow to investigate accidents and ensure injured workers are provided
                     treatment, as well as how to identify hazards.


Medical Management   The ergonomics program has strong links with medical management staff
                     to ensure early reporting and prompt evaluation. The officials emphasized
                     that having WorkMed, the on-site occupational health clinic, has helped
                     SOCHS encourage employees and managers to report all incidents early.
                     This is done through the Report of Employee Incident form as well as by
                     employees’ directly contacting WorkMed for an evaluation. WorkMed is
                     generally able to treat all injured employees.82 Because WorkMed conducts
                     workstation evaluations, it is also able to suggest controls to reduce
                     hazards and injuries and work with the engineering and facilities staff to
                     apply ergonomic principles to equipment purchase and design.

                     SOCHS  has also used restricted- and transitional-duty assignments in an
                     effort to return injured employees to work. Officials said this was a major
                     emphasis for them, since the large number of workers’ compensation
                     claims with lost workdays was a basis for their inclusion in Maine 200. In
                     fact, when SOCHS began this program, a number of employees were out on
                     disability, and SOCHS immediately tried to get them back to work on
                     restricted duty. To control the number of days employees are out, officials
                     maintain contact with injured employees, and the risk management


                     82
                      WorkMed also provides other personnel services, such as drug testing and preplacement evaluations
                     of prospective employees to determine whether they have any preexisting conditions or injuries that
                     may affect their ability to perform the required tasks. WorkMed provides services to about 300 other
                     employers in addition to SOCHS employees.



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                     The Ergonomics Program at SOCHS,
                     Lewiston, Maine




                     coordinator sends calendars to cognizant supervisors to help them track
                     the number of days their employees are out or on restricted duty.

                     WorkMed follows up with these employees once they are back at work.
                     After each physical examination it performs, WorkMed determines
                     whether an employee needs any type of restriction. If so, WorkMed
                     completes a “Patient Instruction Form,” which documents the
                     recommended treatment for the injury or reported discomfort and
                     highlights the activities the employee can do and for how long. Through
                     the workstation evaluations, WorkMed ensures that the employee’s
                     workstation supports these restrictions.

                     Officials said that because SOCHS is so large, finding these types of jobs for
                     injured employees is not difficult. The medical center has developed
                     several light-duty positions, such as answering the telephone for lifeline
                     calls or doing research on the library computer. The nursing home has
                     established an area in its laundry room where employees can be assigned
                     during recovery time. The officials said the individual departments carry
                     the charges for these jobs, so they have an incentive to return employees
                     to full performance as soon as possible. Despite this, officials did say that
                     some employees in the system were so badly restricted that ensuring that
                     they are productive has been difficult.


                     SOCHS   officials said they were generally satisfied with the results of their
Results and Issues   program because of (1) the reductions in injuries and their associated
Related to Program   workers’ compensation costs and (2) an improved safety and health
Performance          record, as evidenced by both facilities’ “graduation” from Maine 200 in
                     1996. Eligibility for graduation from the Maine 200 program was
                     determined by OSHA on the basis of the extent to which it believed the
                     facilities had implemented the goals of the Safety and Health Program
                     Management Guidelines,83 not on whether the facilities met specific
                     targeted reductions in injuries, claims, or costs. After working with SOCHS
                     for this 2-year period, reviewing SOCHS’ quarterly progress reports, and
                     conducting several on-site monitoring visits, OSHA determined that SOCHS
                     had made sufficient progress in implementing its safety and health
                     program. Despite this success, officials said a number of factors needed to


                     83
                       The specific requirements included clearly identifying the people assigned to safety and health
                     responsibilities, providing for employee involvement in safety and health matters, developing a system
                     for investigating all accidents to identify all contributing causes, having a plan to encourage employees
                     to report hazards to management as soon as possible to enable management to address such hazards
                     promptly, developing a comprehensive training program, and having a job hazard analysis program or
                     its equivalent to analyze every job in the facility.



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                         The Ergonomics Program at SOCHS,
                         Lewiston, Maine




                         be considered when reviewing these results that often complicated their
                         ability to tie results directly to their efforts.


Reductions in Workers’   As figure VI.I shows, the medical center and nursing home together
Compensation Costs       reduced workers’ compensation costs for MSDs by about 35 percent
Associated With MSDs     between 1994 and 199684 (from $100,000 to about $70,000). To capture
                         MSDs, SOCHS tracks “cumulative trauma disorders” (for example, “carpal
                         tunnel syndrome” and “overuse syndrome”); “tendinitis”; “epicondylitis”;
                         and “back injuries.”85 However, the average cost for MSD workers’
                         compensation claims for both facilities combined increased slightly, from
                         about $2,500 in 1994 to over $3,000 in 1996 (see fig. 3).




                         84
                           As discussed in app. I, the years of data provided for each facility differ depending upon when facility
                         officials believe the current program was fully implemented. In most cases, we present data from the
                         year prior to the full implementation of the program through 1996 in order to show changes that
                         occurred at the facility during the years of the ergonomics program’s operation. For SOCHS, since the
                         program was fully implemented in 1994, we ordinarily would present data beginning in 1993. However,
                         SOCHS data for 1993 are not comparable with those of later years because SOCHS became self-insured
                         in Oct. 1993. As a result, workers’ compensation data presented are for 1994-96.
                         85
                          Officials said that not all back injuries are necessarily due to ergonomic hazards. To determine
                         whether back injuries are due to ergonomic hazards, it would be necessary to review the conditions
                         surrounding the incident.



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                                     Appendix VI
                                     The Ergonomics Program at SOCHS,
                                     Lewiston, Maine




Figure VI.1: Workers’ Compensation
Costs for MSDs at SOCHS’ Medical     120      Total Dollars for MSD Claims (in Thousands)
Center and Nursing Home, 1994-96              111       110


                                     100



                                      80
                                                                  72


                                      60



                                      40



                                      20



                                          0

                                                1994     1995      1996
                                                Calendar Year



                                     Note: Workers’ compensation data were not available for 1993, the year before the full
                                     implementation of the program, because SOCHS was insured through a carrier for most of the
                                     year and only has information on premiums paid. As a result, this figure uses 1994 as the base
                                     year for presentation of data.

                                     Source: SOCHS’ workers’ compensation database.




                                     SOCHS  officials said other evidence of success has been the reduction in the
                                     amount needed to fund SOCHS’ workers’ compensation trust. After the first
                                     year of being self-insured, SOCHS has been allowed to set aside decreasing
                                     amounts of funds and can now set aside funds as it believes are necessary.
                                     If the trust becomes larger than SOCHS believes is required, it can withdraw
                                     any excess funds. In 1996, SOCHS withdrew $800,000.

                                     Nonetheless, the officials said a number of issues need to be considered
                                     when evaluating these data. First, when SOCHS implemented its program,
                                     officials found the existing systems were inadequate to track injury and
                                     claim experience, so SOCHS developed two databases—one based on the
                                     Report of Employee Incident form and the other based on workers’
                                     compensation claim experience.86 These databases help SOCHS officials
                                     monitor injuries and claims, but officials said they do not typically isolate

                                     86
                                       This database is operated by SOCHS’ third-party administrator.



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                             Appendix VI
                             The Ergonomics Program at SOCHS,
                             Lewiston, Maine




                             injuries that would be categorized as MSDs because SOCHS has sought to
                             reduce all types of injuries and their associated costs. Officials said it
                             could be difficult to isolate MSDs from other injuries, since doing so would
                             require that all Report of Employee Incident forms be reviewed to fully
                             understand the circumstances of the incidents and, thereby, determine
                             whether the injuries resulted from ergonomic hazards.

                             Officials also said costs can be significantly affected by one or two large
                             claims. For example, in 1996, the medical center had a total of 179 lost
                             workdays, 157 of which resulted from one claim. Thus, this one claim was
                             in large part responsible for the increase in average MSD cost discussed
                             above. Officials also said the number of incidents is likely to increase
                             because early reporting is being encouraged.

                             Moreover, officials said it was difficult to know how much of a reduction
                             in injuries, illnesses, and associated costs is appropriate. They agreed that
                             it was appropriate for OSHA not to impose specific performance goals, such
                             as a certain percentage reduction in workers’ compensation costs, given
                             the newness of the program. The officials said program results must be
                             viewed over the long term, because they believed the key was to look for a
                             process that improves from year to year.


Reductions in Injuries and   The OSHA 200 log data are instructive because they illustrate a facility’s
Illnesses According to the   general experience with injuries and illnesses, and these data are used by
                             OSHA in its inspection efforts. According to data for the medical center and
OSHA 200 Log
                             nursing home combined for 1993 through 1996,87 the number of injuries
                             and illnesses for every 100 employees (the incidence rate) declined from
                             14.7 to 12.3 (see fig. 4). The experience between the two was uneven,
                             however, with the nursing home experiencing an increase in injuries and
                             illnesses over this period. But the significant reductions at the medical
                             center enabled SOCHS, as a whole, to realize a reduction in the incidence
                             rate. And, for 1995, the last year for which industry comparison data are
                             available, the nursing home’s incidence rate of 17.3 was lower than the
                             industry average for nursing and personal care facilities of 18.2, and the
                             medical center rate of 8.6 was below the industry average for hospitals of
                             10.1. Additionally, while the facilities together were able to reduce the
                             number of lost workdays for every 100 employees by 35, the number of
                             restricted days for every 100 employees for both facilities combined
                             actually increased by 45 (see fig. 2).

                             87
                              OSHA 200 log data were available for 1993, the year before the full implementation of SOCHS’
                             program. Because so few years of data were available for workers’ compensation costs for MSDs, we
                             decided to use 1993 for the base year for presentation of OSHA 200 data.



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                             The Ergonomics Program at SOCHS,
                             Lewiston, Maine




                             The officials said reduction of lost workdays was important for them
                             because the medical center and the nursing home were selected for
                             inclusion in the Maine 200 program because of their large number of
                             claims with lost days. As a result, officials said the increase in the number
                             of restricted days reflects their efforts to keep injured employees at work
                             on restricted work assignments or to return employees to work as soon as
                             possible. Also, as evidence of its return-to-work policy, last year, SOCHS did
                             not have to pay any workers’ compensation for nursing home employees’
                             salary or benefits while they were out of work.88

                             Officials said they do not primarily use the OSHA 200 log to track program
                             progress. In fact, they said they had to develop other systems when they
                             first began the program because the OSHA 200 log data were piecemeal and,
                             in some cases, inaccurate. Moreover, officials said OSHA 200 did not allow
                             for sufficient information to be entered about the cause of the injury or
                             illness.


Improvements in              SOCHS  officials believed that their emphasis on ergonomics, and safety and
Productivity, Quality, and   health in general, had contributed to an improved work environment, but
Morale                       evidence of this was largely anecdotal. Officials believed that the program
                             had contributed to reduced turnover and absenteeism, and the better work
                             environment has meant that SOCHS can attract the best employees away
                             from competitors. In some cases, ergonomic improvements have also
                             contributed to increased efficiency and effectiveness; for example, some
                             of the equipment redesigns have eliminated duplication in the processes
                             SOCHS uses to enter data. Officials also said that employee morale has
                             improved, as evidenced by employees’ appreciation and use of the
                             automatic lifts. In response to employees’ demands, SOCHS is now buying
                             additional automatic lifts for use in other areas. This is significant, given
                             that there was some resistance when the lifts were first instituted.




                             88
                               In Maine, employees must use their own accrued leave for the first 4 days they are out for any injury;
                             the next 4 days are covered under a short-term disability fund. As a result, workers’ compensation is
                             not triggered until the ninth day, or after 56 hours. Because no injured employees at the nursing home
                             were out for more than 8 days in 1996, SOCHS did not have to expend any workers’ compensation
                             costs on salary or benefits.



                             Page 115                                  GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix VII

The Ergonomics Program at TI, Defense
Systems and Electronics Group
Headquarters, Lewisville, Texas
               Texas Instruments, which began operation in 1951, is a manufacturer of
Background     semiconductor devices; electronic sensors; and radar, navigation, and
               missile guidance systems. TI has about 55,000 employees worldwide in
               about 150 locations.

               The Lewisville, Texas, facility of TI, which began operation in 1978, serves
               as the headquarters of the Defense Systems and Electronics Group
               (Systems Group) for TI. The Systems Group, which includes Lewisville and
               four other nearby facilities, produces the “smarts,” or electronics, for
               weaponry. About 2,800 employees are employed at Lewisville, with
               engineers composing about two-thirds of the staff. Other occupations at
               Lewisville include electrical assemblers, machinists, manufacturing aides,
               and equipment technicians. None of the workforce is unionized.

               TI’scorporate culture, which reflects quality management principles,
               affects TI’s ergonomics efforts. Beginning in the early 1990s, TI adopted a
               team-based organizational structure. Many different teams have been
               formed at the facility level, the Systems Group level, and the corporate
               level to address a wide range of production and other issues, including
               safety and health. TI drives its activities by setting corporationwide goals
               and providing considerable flexibility at the various levels of the
               organization to achieve these goals. The overall goals and targets are set
               through a negotiation process between corporate management and these
               teams. As consistent with quality management principles, TI has
               encouraged the diffusion of best practices across sites. The Systems
               Group Ergonomics Council was formed in 1993 to facilitate sharing of
               information across the Systems Group. Also, a Global Ergonomic
               Leadership Team was formed at the corporate level to build a corporate
               communication strategy. TI also participates in an informal consortium of
               Texas companies called the North Texas Ergonomics Consortium.

               The industry type and product line also affect TI’s ergonomics efforts. The
               Lewisville facility was described as a “lean and agile” operation that
               undergoes rapid changes in production activity. For example, as
               production in some work areas is “ramping up,” in others, it is “ramping
               down.” A recent consolidation resulted in some staff and operations from
               other facilities being transferred to Lewisville. These constant changes can
               be challenging to teams trying to reduce ergonomic hazards. In addition,
               the federal government is a major customer for the products at Lewisville,
               which places some constraints on the flexibility the facility has to modify
               its production practices. Also, because of Lewisville’s dependence on
               federal contract dollars, the facility underwent some downsizing between



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                     The Ergonomics Program at TI, Defense
                     Systems and Electronics Group
                     Headquarters, Lewisville, Texas




                     1992, when it had about 3,700 employees, and 1996, when approximately
                     2,800 employees were employed at this facility.


                     The ergonomics program at Lewisville was fully implemented in 1992, the
Initiating the       year after workers’ compensation costs for MSDs exceeded $2 million,
Ergonomics Program   causing considerable alarm among facility management. TI’s ergonomics
at Lewisville        efforts, including those at Lewisville, appear to have evolved, however,
                     with some activities dating back to the 1980s.

                     An extensive ergonomics awareness training effort was initiated by the
                     site safety engineer at Lewisville in the 1980s. The next site safety
                     engineer, who still holds this position, specializes in ergonomics. In 1989,
                     an ergonomics thrust was proposed by the Lewisville Site Safety Council.
                     Special corrective action teams (CAT) were formed to address specific
                     ergonomic problems, such as replacing worn hand tools and redesigning
                     totes for material handling that would cause less strain. Although the
                     individual CATs attacked some special problems, each was dissolved once
                     a solution was proposed.

                     In 1991, a standing ergonomics team, Lewisville’s ergonomics team, was
                     formed, and a second wave of ergonomics training was initiated
                     throughout the manufacturing work areas. “ERGO Days”—special days on
                     which participatory, educational displays were set up throughout the
                     facility to foster awareness of ergonomic issues and during which
                     employees’ personal workstation measurements were taken—were begun
                     in 1992. The ergonomics team also conducted incident evaluations when
                     injuries occurred and started an effort to adjust administrative
                     workstations. However, because the team was staffed by Lewisville
                     employees who volunteered to do this in addition to their other duties, it
                     was limited in what it could accomplish. In some cases, considerable
                     delays occurred between when an injury was reported and when team
                     members could find time to conduct an evaluation.

                     When a full-time ergonomics specialist position was created in 1995, the
                     ergonomics team began to address the MSD problem more aggressively,
                     according to the current team leader. A facility team of program
                     managers—referred to as the Site Safety Quality Improvement Team
                     (QIT)—had agreed to create this position because the ergonomics team had
                     successfully argued that its inability to follow through on reports of
                     injuries was a barrier to the facility’s reaching its safety and health goals.




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                        The Ergonomics Program at TI, Defense
                        Systems and Electronics Group
                        Headquarters, Lewisville, Texas




                        In 1996, the ergonomics team was reorganized to include a cross section of
                        facility employees.


                        The heart of the ergonomics program at Lewisville is its ergonomics team,
Structure and Core      to which the full-time ergonomics specialist and the site safety engineer
Elements of the         provide support. Other teams formed for broader objectives within the
Program at Lewisville   Lewisville facility, across the entire Systems Group, and throughout the
                        corporation provide guidance and direction to the ergonomics team. These
                        teams, including the Site Safety QIT, which is composed of program
                        managers, communicate focus and strategy to the Lewisville Site Safety
                        Council, of which the ergonomics team is a subteam.

                        The Systems Group Ergonomics Council communicates focus and overall
                        direction on ergonomic activities across the Systems Group. It reports
                        upward to two teams that support numerous ergonomic activities and also
                        operate across the Systems Group: the Systems Group Environmental,
                        Safety, and Health Leadership Team and the Systems Group Human
                        Resources Leadership Team. These teams in turn feed into the Systems
                        Group Leadership Team. At the corporate level, there are the Corporate
                        Environmental Safety and Health Leadership Team and its subteam
                        specific to ergonomics, the Global Ergonomics Leadership Team, which
                        was formed just a year ago. The activities of the Global Ergonomics
                        Leadership Team include building a better communication strategy that is
                        truly global (since TI has facilities worldwide). Also at the corporate level
                        is the staff office for Corporate Environmental Safety and Health.


Management Commitment   Management commitment to the ergonomics program at Lewisville is
                        demonstrated in a number of ways. Primary among them is the assignment
                        of staff, including the ergonomics team and a full-time ergonomics
                        specialist hired in 1995 to help the team achieve its objectives. The site
                        safety engineer said that the facility probably waited “too long” to hire the
                        ergonomics specialist, which delayed implementation of the ergonomics
                        program since neither the members of the ergonomics team nor the site
                        safety engineer could respond quickly enough to problems.

                        Corporationwide accountability mechanisms are reflected in the corporate
                        strategic goal, which all facilities are expected to contribute toward
                        achieving. This overall goal is to eliminate all preventable occupational
                        and nonoccupational injuries and illnesses by the year 2005. To do so,
                        since 1996, facilities have strived for a 20-percent reduction from the



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Appendix VII
The Ergonomics Program at TI, Defense
Systems and Electronics Group
Headquarters, Lewisville, Texas




previous year in the injury and illness incident rate and the lost or
restricted day rate. In addition, a corporationwide audit is conducted by
the Corporate Environmental Safety and Health office at each facility once
every 3 years. Through these audits, TI tries to ensure that each facility is
following practices consistent with the company’s Ergonomic Process
Management Standard, which lays out minimum requirements for the core
elements of an ergonomics program that each facility must meet. Each
facility also conducts a self-audit every year using these same guidelines.

Ergonomic principles are also integrated into purchasing and design. For
example, a future project of the ergonomics team, the Integrated Product
Development Process, will involve working with facilities staff, product
designers, and assemblers to see how ergonomics can be better integrated
into product development. In addition, the ergonomics team, working with
other teams across the Systems Group, has undertaken various projects
for the design or purchase of ergonomic tools. For example, another
facility within the Systems Group has developed an Ergonomic Hand Tool
Catalog from which employees from any Systems Group facility can select
tools that meet preset standards and that have been widely tested within
the facility itself.89

Resources are also made available for the ergonomics program.
Suggestions for controlling problem jobs that are submitted by the
ergonomics team are typically accepted by facility management. Because
the cost center managers are also members of the Site Safety QIT (which
can approve most expenditures directly), formal cost justifications are
rarely required for capital investments to control ergonomic hazards. A
written cost justification is required only if a control costs more than
$1,500. In fact, any of these larger capital investments must also be
approved by the site safety engineer to ensure that no safety or health
(including ergonomic) concerns are associated with it.

The facility has also established mechanisms for ensuring that middle
management support is sustained. The Site Safety QIT is composed of
program managers who provide overall focus and strategy to the
ergonomics team and also approve most capital investments to improve
ergonomic conditions. Also, in recognition of the importance of middle
management buy-in, two “Ergonomic Management Seminars” were
sponsored in 1996. Some of the managers had been skeptical of the need
for the ergonomics program, perhaps since they had never experienced an

89
  A manager at this other facility made money available out of his own budget to purchase tools,
thereby expanding the hand tool effort there. Less money is available at Lewisville for purchasing
these tools.



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                       Appendix VII
                       The Ergonomics Program at TI, Defense
                       Systems and Electronics Group
                       Headquarters, Lewisville, Texas




                       MSD—and   they may be less likely to, since their job responsibilities tend
                       not to pose the same risks. Yet the ergonomics team considered buy-in
                       from these middle managers critical, since they often controlled the cost
                       centers toward which any ergonomic investments would be charged.
                       These management seminars demonstrated how ergonomic losses affect
                       the bottom line by discussing the cost of injuries and the impact of MSDs on
                       productivity.

                       TI’s Ergonomic Site Policies and Procedures lays out specific
                       responsibilities of various teams and facility staff for implementing the
                       core elements of the ergonomics program. For example, this document
                       requires the Site Safety QIT to continue to demonstrate visible support for
                       the ergonomics program. Similarly, production engineering department
                       staff are required to document ergonomic analysis for all future
                       workstations and serve as ergonomic incident investigators for work areas
                       they support. But this document is not viewed by corporate or facility staff
                       as key to program operations, and team members said they rarely refer to
                       it.90


Employee Involvement   Employee involvement is illustrated by the central role the ergonomics
                       team plays in all ergonomic activities at the facility. This team is composed
                       of a cross section of staff from the engineering, warehouse, space
                       planning, and medical departments as well as from TI’s fitness club. There
                       are more engineers on Lewisville’s ergonomics team than there are on
                       some other TI ergonomics teams, which, according to the team leader,
                       reflects Lewisville’s emphasis on developing controls specifically tailored
                       to the needs of individual production units. In addition, the team leader is
                       also a manager in the production engineering department. The team
                       oversees the ergonomic program and the activities of the ergonomics
                       specialist, and can make capital requests. Participation on the team is
                       voluntary and involves a 2-hour meeting every 2 weeks and perhaps 1 hour
                       of “homework” every week. However, it is the ergonomics specialist who
                       is responsible for the day-to-day activities of identifying problem jobs and
                       developing controls.

                       Employees are involved in an ad hoc fashion as well. They are encouraged
                       to go directly to the ergonomics specialist or production engineering
                       department to identify potential controls for their own jobs when they
                       believe ergonomic hazards exist. Solutions or controls proposed by the

                       90
                        A corporate safety official said this document is based on OSHA’s 1990 voluntary guidelines for the
                       meatpacking industry.



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                                Appendix VII
                                The Ergonomics Program at TI, Defense
                                Systems and Electronics Group
                                Headquarters, Lewisville, Texas




                                ergonomics specialist or the ergonomics team are also critiqued by
                                assembly and other employees who work on the problem job.

                                Procedures have been established so that employees can directly access
                                ergonomic services. An employee can request an administrative or
                                manufacturing workstation evaluation either in person, by phone, or via
                                electronic message. The employee is then automatically visited by the
                                ergonomics specialist, who administers a one-page “Ergonomics
                                Evaluation Report” (one version for administrative workstations and
                                another version for manufacturing workstations). Once measurements are
                                taken by the ergonomics specialist, they are entered into a database so
                                that any workstation the employee moves to within this or another TI
                                facility is properly adjusted to meet that employee’s personal
                                requirements.

                                Lewisville also conducts a number of awareness campaigns, including its
                                “wing-by-wing” measurement campaign, in which employees are measured
                                and their workstations adjusted. This is particularly helpful for employees
                                who may be experiencing problems but have not yet requested services.
                                As part of this campaign, ergonomic accessories are suggested to
                                individual employees and ordered, and the ergonomics team works with
                                cost center managers to purchase equipment or anything else that the
                                employee needs. In addition, Lewisville offers a wide range of training and
                                awareness activities, which are catalysts for effective participatory
                                ergonomics, according to the facility’s ergonomics training coordinator.
                                (These training and awareness activities are described below).


Identification of Problem       There are several ways in which the ergonomics team and the ergonomics
Jobs                            specialist learn that a job might be a problem. Incidence-based methods
                                for identifying problem jobs, that is, methods that rely on employee
                                reports of injury or discomfort or employee requests for assistance, follow:

                            •   When an accident occurs or an employee reports an injury or illness to the
                                health center, the supervisor or “safety starpoint”91 must investigate the
                                incident and complete an “Injury/Illness “Investigation Report.” This
                                report, which is submitted to the Accident Review Board of the safety
                                department, is intended to identify root cause in order to prevent another
                                employee from being injured in the same way. The employee is evaluated
                                and treated at the health center. If the injury involves “body stress” or

                                91
                                 A safety starpoint is an employee within each work team who is responsible for helping with accident
                                or incident evaluations and disseminating information regarding safety, which includes providing
                                safety training, to members of the team.



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                              Headquarters, Lewisville, Texas




                              “repetitive motion,” the ergonomics specialist is notified and is required to
                              conduct a job or worksite analysis within 3 working days.
                          •   Any employee who is experiencing discomfort can request either an
                              administrative or manufacturing workstation evaluation simply by sending
                              an electronic message to the ergonomics specialist.
                          •   Jobs in all “at-risk” job classifications—that is, jobs with a high number of
                              recordable injuries or illnesses—are identified through a review of the
                              injury and illness data in the facility’s workers’ compensation database.
                              Among the at-risk jobs identified were production helper, optical
                              fabricator, parts finisher, and electrical assembler.92

                              The following methods for identifying problem jobs on a proactive
                              basis—to avoid injuries on jobs at which there was evidence that hazards
                              existed—were used:

                          •   A “wing-by-wing” measurement campaign was instituted to measure
                              employees and adjust their workstations as a way of identifying employees
                              who might be experiencing problems. This campaign offers one-on-one
                              educational opportunities to employees who otherwise may not have
                              sought out help, according to a member of the Site Safety QIT.
                          •   An administrative workstation adjustment campaign was implemented in
                              recognition of the facility’s need to shift its focus from hazards at the
                              manufacturing workstation—many of which the company had already
                              addressed—to potential hazards at administrative workstations. Many
                              employees at Lewisville use both types of workstations.93

                              Prioritizing problem jobs is done by the ergonomics team on the basis of
                              jobs, or job classifications, where injuries have already occurred. In other
                              words, the ergonomics team has focused first on jobs in which an
                              employee, who has reported to the health center, is found to have an MSD
                              or related symptoms. A second priority has been addressing at-risk job
                              classifications with the help of a consultant.


Analyzing Problem Jobs        Facility officials described analyzing problem jobs and developing controls
and Developing Controls       as generally an “informal” process. The ergonomics specialist referred to

                              92
                                The analysis of all at-risk jobs, which involved examining at least several jobs within each of these
                              job classifications and developing specific training for employees in these work areas, is 95-percent
                              complete. However, controls have not necessarily been fully implemented in all of these job
                              classifications, according to the team leader.
                              93
                                Lewisville had a target of measuring employees and adjusting the workstations of 90 percent of
                              administrative staff by 1996. While the 1996 goal was missed, Lewisville had measured and adjusted
                              the workstations of 72 percent of administrative staff as of March 1997.



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                               many of his activities as workstation evaluations as opposed to job
                               analyses because these activities focused on increasing the employee’s
                               comfort in relation to his or her workstation but did not involve major
                               changes to the job or operations. Sometimes, however, more detailed
                               analysis is conducted, particularly for at-risk jobs, and this facility has
                               used the services of a consultant to help develop controls.

                               The ergonomics specialist said that developing controls is an “iterative”
                               process, but that typically something can be done to reduce ergonomic
                               hazards, even if it is just talking to the employee to identify work practices
                               that may be contributing to the problem. Many of the controls
                               implemented could be described as “low-tech” engineering controls, such
                               as purchasing adjustable-height workstations and “ergoscopes”
                               (ergonomic microscopes) to improve employees’ comfort while they
                               manually touch up or rework circuit boards. So even though some jobs
                               required more detailed job analyses, the controls implemented were still
                               relatively simple.

Process Used to Analyze Jobs   To analyze a problem job, the ergonomics specialist administers the
                               one-page Ergonomics Evaluation Report whenever an employee requests
                               that his or her workstation be evaluated. The employee can make the
                               request to the ergonomics specialist by electronic message or face to face,
                               since the ergonomics specialist often walks the floor of the facility so that
                               he is accessible to all staff. Both the administrative and manufacturing
                               workstation versions of the form ask for personal measurements and
                               workstation descriptions and provide space for short- and long-term
                               recommendations; the manufacturing workstation form also asks for risk
                               factors. Once the employee measurements are taken, they are entered into
                               a database so that any workstation the employee moves to within this or
                               another TI facility can be properly adjusted to his or her personal
                               requirements.

                               If an injury is reported to the health center, more information is collected
                               by the health center staff and the ergonomics specialist. The “Ergonomic
                               Evaluation Questionnaire” is several pages long and captures information
                               on the frequency of tool or equipment use, the types of tasks performed,
                               characteristics of the workstation if a computer is used, the types of
                               physical activities the worker performs, the type of pain experienced, and
                               activities outside of work that may be contributing to the problem. All of
                               this information is provided by either the employee or the ergonomics
                               specialist. Health center staff complete the part of the questionnaire that




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                          The Ergonomics Program at TI, Defense
                          Systems and Electronics Group
                          Headquarters, Lewisville, Texas




                          asks for the employee’s basic medical history, results of various
                          ergonomic-related medical tests, and nursing interventions or treatment.

                          For the more extreme at-risk jobs, this facility provides a more detailed
                          job analysis, which involves videotaping the job and collecting additional
                          documentation. For example, the ergonomics specialist worked with a
                          consultant to analyze and develop controls for the manual electronic
                          assembly job, the job classification in which workers have experienced the
                          highest injury rates. This job was videotaped in order to identify the
                          source of the problem. However, the controls ultimately developed for
                          such jobs are not necessarily complex even if they required more detailed
                          analysis (see app. II). In addition, the consultant made a number of
                          recommendations regarding Lewisville’s manufacturing and warehousing
                          operations. Because recommendations for these controls came from the
                          consultant, the ergonomics team found it was easier to get management
                          buy-in for necessary job changes.

Process Used to Develop   Controls are typically developed informally by the ergonomics specialist,
Controls                  who “brainstorms” with other staff. First, the ergonomics specialist
                          discusses the problem with the employee and the employee team assigned
                          to the job. The ergonomics specialist also consults with the line supervisor
                          (who is also the cost center manager for that particular work area) to get
                          additional ideas for controls as well as buy-in for any changes to a problem
                          job. The cost center manager can typically approve any capital
                          expenditures within that work area.

                          Lewisville makes significant use of its in-house resources in developing
                          controls. The ergonomics team comprises mostly engineers, which,
                          according to the team leader, reflects an emphasis on developing controls
                          specifically tailored to the needs of individual production units. Staff from
                          the production engineering department are brought in to consult on more
                          complex or technical jobs. Although the ergonomics team is not
                          responsible for actually developing controls for specific problem jobs, the
                          team does contribute to the selection of equipment, including personal
                          protective equipment, and makes suggestions about workstation design
                          and job rotation. Individual team members might be called in to advise on
                          how to control a specific problem job. The ergonomics team is now trying
                          to capture information on best practices and make this accessible to all
                          employees and facilities through an Internet home page created for
                          ergonomics issues.




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Once problem jobs are identified, no specific threshold is used to
determine whether or not a control must be put in place. The ergonomics
specialist explained that some action is typically taken for each and every
job where there is a problem. In fact, the ergonomics specialist said there
is value even in just talking to the employee on the problem job because
the ergonomics specialist can sometimes identify bad work practices that
are contributing toward his or her discomfort.

To ensure that controls are effective over the long term, the facility also
has developed a database that contains the results of administrative
workstation evaluations. This information is used when an administrative
employee relocates (which happens frequently) to ensure that the
employee’s new workstation is set up right the first time.

The process is really “never finished” and involves continuous monitoring,
according to the team leader and the ergonomics specialist. Regular
walk-throughs of the facility are conducted by the ergonomics specialist to
enhance awareness and increase accessibility of ergonomic assistance to
employees. Both the health center staff and the ergonomics specialist
follow up on employees who have reported injuries or symptoms to the
health center. Employees on the job, and other assembly and engineering
staff, also provide feedback on how well controls are working.

Illustrating the iterative nature of developing controls, when an
adjustable-height workstation design was tested on the production floor,
employee feedback revealed that this design was unstable and allowed
products to fall off. Using this feedback and working with a vendor, the
ergonomics team and specialist developed a new design. The result was an
adjustable table, referred to as “Big Joe,” which was essentially a fork lift
with its wheels removed. This design proved to be much more stable.

In some cases, the ergonomic hazard cannot be totally eliminated. One job
that has been difficult for Lewisville to control involves the need for
employees to fit wire harnesses into small openings of a potting mold in
order to protect connectors from vibration inside the missile. This job
requires considerable force, since the hand must be used as a clamp to fit
the wiring into place. While the ergonomics specialist has experimented by
having employees use pliers and different connectors and has asked
tooling engineers to look at the job, no satisfactory engineering control
has yet been developed.




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                                The Ergonomics Program at TI, Defense
                                Systems and Electronics Group
                                Headquarters, Lewisville, Texas




                                Lewisville has discovered that sometimes minor changes in product design
                                can have a major impact on reducing ergonomic hazards. An example of
                                this involved the task of painting the inside of a particular type of missile.
                                Employees were getting injured and experiencing discomfort from
                                twisting and turning their wrists to paint in this confined space. After
                                discussing the problem with the government contracting officers,
                                Lewisville officials learned that the customer did not really need this
                                product to be painted—that this had been required by military
                                specifications that were now outdated. As a result of these discussions,
                                this task was eliminated, significantly reducing the ergonomic hazards
                                associated with the job.

                                Investments in technological advances in the electronics industry that
                                have improved productivity or product quality have also led to ergonomic
                                improvements—even though this was not necessarily the objective of
                                these investments. By automating many of the steps in circuit board
                                assembly over the last decade, Lewisville has eliminated much of the
                                manual assembly work and, thereby, the associated ergonomic risks. For
                                example, a stainless steel stencil is now laser-etched onto the board, an
                                automated squeegee applies the paste to the board, and the boards are
                                then fed into a machine that loads components via feeder reels and chip
                                shooters. In these highly automated work areas, there are few ergonomic
                                hazards.

Types of Controls Implemented   A mix of controls is employed. However, priority is given to engineering
                                controls over administrative controls, which are viewed as an “interim
                                solution.” Many of the engineering solutions, however, are relatively
                                simple or “low-tech,” involving, for example, modifications to
                                workstations so they are more comfortable for the user. These low-tech
                                engineering solutions include installation of adjustable-height
                                workstations, replacing older microscopes with more comfortable
                                “ergoscopes,” placing padding along the edges of the workstation, and
                                raising the circuit boards with foam for hand-intensive work. Hoists are
                                used to load multiple circuit boards (which can weigh up to 60 pounds)
                                into a vapor system machine to be primed and coated.

                                Many of the “low-tech” controls are also low cost. Average cost estimates
                                developed by the ergonomics team for the Site Safety QIT are $15 to $20 for
                                changes to administrative workstations and $50 to $1,000 for changes to
                                manufacturing workstations. Only if a special tool is required (which is not
                                often, according to the ergonomics team leader) to address a problem at a
                                manufacturing workstation are costs significantly greater. Virtually every



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                         The Ergonomics Program at TI, Defense
                         Systems and Electronics Group
                         Headquarters, Lewisville, Texas




                         workstation improvement can be made without going through the facility’s
                         capital approval cycle, which is required for investments over $1,500.

                         “High-tech” engineering controls, however, are sometimes necessary. For
                         example, the production engineering department developed a laser welder
                         to eliminate some of the hand soldering required in the production of
                         microwave circuit boards. Removing the coating around components to
                         fix a faulty circuit board has also been automated with the use of a
                         “microblaster.” Before the microblaster, workers had to pick off the
                         coating using tweezers.

                         Administrative controls are also used, particularly when it is not
                         economical or feasible to implement engineering controls. For example,
                         Lewisville is currently “ramping down” its production of one type of
                         missile. Therefore, job rotation is being used on problem jobs related to
                         the production of this missile to minimize employees’ exposure to hazards.

                         Another type of administrative control used at Lewisville is its “stretch
                         program.” Currently, employees in most of the work areas take 10- to
                         15-minute stretch breaks twice a day. The purpose of the stretch breaks is
                         to reduce both the physical and psychosocial stress of repetitive work and
                         exposure to other ergonomic hazards. In addition, stretch breaks have
                         sometimes led to employees’ asking to have an ergonomics team member
                         look at a work process or workstation and help them find a more
                         comfortable solution, although, according to the ergonomics training
                         coordinator, some managers at first felt that the stretch program was “a
                         waste of time.” However, since implementing this program, participants
                         have reported that they feel better and are less fatigued, and some of the
                         managers who were previously skeptical have been pleased by these
                         results. One at-risk work area—where the majority of all injuries and
                         illnesses at the facility had previously been recorded—found that MSDs
                         dropped dramatically after instituting stretch breaks, which has
                         contributed to an improved injury and illness incidence rate for the facility
                         as a whole.


Training and Education   All employees at the Lewisville facility are required to take a general
                         ergonomics awareness course. Each employee must take at least 1 hour of
                         this training every 3 years.94 Although training staff had initially proposed
                         that this course be longer and offered annually, facility management was

                         94
                          TI as a company places a heavy emphasis on training, according to the ergonomics training
                         coordinator. All employees are required to take 40 hours of educational training each year.
                         Ergonomics training can be applied toward this 40-hour requirement.



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concerned that this was too much of a time commitment. As a result, the
awareness training requirement was reduced.

Lewisville also offers a wide range of both general awareness activities
and targeted ergonomics training. “ERGO Days,” for example, is an annual
3-day event sponsored by the ergonomics team. Team members develop
participatory, educational displays set up throughout the facility featuring
best ergonomic practices for work and the home, computer accessories,
tool demonstrations, and ergonomic workstation adjustments. Similarly,
the “wing-by-wing” measurement campaign and the administrative
workstation adjustment campaign spread awareness and include a
one-on-one educational component. The ergonomics team also sponsors
hand tool demonstrations for engineers, technicians, assemblers, and
purchasers. These demonstrations are educational in nature in that they
discuss, for example, the importance of replacing worn tools. In addition,
Lewisville staff can access an Internet ergonomics home page. Finally, the
Lewisville facility publishes an environmental, safety, and health
newsletter that often features articles about ergonomics.

Training opportunities provided to employees are (1) site specific, so
instruction is relevant to the employee (for example, photos and
videotapes of work areas are taken to facilitate class discussion, and
training is conducted within a team’s work area); (2) interactive and often
team based, with emphasis on problem solving and practical solutions (the
courses focus on problems employees are experiencing on their jobs,
sometimes without disruption to the production cycle); and (3) results
oriented, in that training staff and management plan courses together, so
specific goals and expectations are agreed upon.

Courses offered at Lewisville include “Ergonomics for Computer Users”
for all employees (including assembly workers if they also use computers)
and “Ergonomic Audit for Computer Users” for all employees who spend
more than 4 hours per day using a computer. The course “Factory
Ergonomics Awareness” is designed to teach individuals how to identify
and correct ergonomically unsound workplace conditions and activities.
This course encourages the actual development and implementation of
controls, with examples taken from participants’ own work areas. At least
95 percent of staff have taken this class. “Advanced Ergonomics for
Electronic Assemblers” is specifically tailored to employees who work in
this at-risk job classification, and team-based instruction is used.95

95
  One problem with team-based instruction, however, is the constantly changing composition of teams.
This means that, particularly when a new team member is added, follow-up is needed to see if the
training is being applied, according to the ergonomic training coordinator.



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                     Assembly teams are taught how to identify risks and to be self directed in
                     addressing problems. “Advanced Ergonomics for Teams that Handle
                     Materials” is another team-based course for an at-risk job classification,
                     which includes on-the-job training as well as classroom training. In this
                     course, the ergonomic specialist helps the team identify a problem and
                     develop and implement controls. A “Back Injury Prevention” course is
                     offered to all personnel who lift as part of their jobs.


Medical Management   Strong links between Lewisville’s ergonomics program and medical
                     management staff have been established to ensure early reporting and
                     prompt evaluation. Lewisville (like every other facility within the Systems
                     Group) has a health center staffed by two contract nurses. A senior nurse
                     serves all four facilities within the Systems Group. Additional medical
                     management staff include the disability coordinator (who is also a nurse)
                     and the lost-time intervention manager. Medical management staff
                     participate on all facility teams for safety, ergonomics, and lost-time
                     intervention. These links were established because medical management
                     staff recognized that, to have an impact on reducing injury and illness
                     rates and their associated economic costs, they needed to participate on
                     various teams to provide input into the facility’s ergonomic activities.

                     The medical management process was described as follows. First, the
                     employee reports to the health center and a physical assessment is made
                     and a medical history is taken. If symptoms or diagnosis of an MSD is
                     involved, the employee is asked to fill out a portion of the Ergonomic
                     Evaluation Questionnaire, which is then sent to the ergonomics specialist.
                     In addition, an Injury/Illness Investigation Report is prepared for the
                     Accident Review Board of the safety department. The ergonomics
                     specialist is supposed to respond within 3 workdays by conducting a job
                     analysis. Follow-up on the employee is done by medical management staff
                     every week, and if there is no improvement, the health center recommends
                     the employee see a doctor.

                     The disability coordinator is responsible for developing a relationship with
                     local health care providers and a list of doctors who are conservative in
                     their treatment approach, are familiar with the work at Lewisville, and
                     understand the facility’s return-to-work program. Because state law
                     precludes the health center from recommending a specific doctor, a list of
                     doctors is provided to employees only if they request it. TI also has a list of
                     preferred providers for hand surgeries if such treatment is called for.
                     Identifying doctors and developing relationships with them have been



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challenging tasks at Lewisville, given the multitude of doctors in the
surrounding Dallas metropolitan area. If the employee is out for 6 days or
more, a special evaluation of the job is performed to help the doctor
determine how the injured employee should be accommodated. If a
determination is made that this MSD is a workers’ compensation case,
regular follow-up is conducted by health center staff and the ergonomics
specialist.

Lewisville also uses its lost-time intervention program to return employees
to transitional or restricted-duty work. This is key to cost savings,
according to the manager of this program, because the company is insured
through a third-party administrator, and TI pays out of pocket if an
employee stays at home. In addition to cost savings, Lewisville’s
return-to-work program also offers other benefits, according to medical
management staff: communication between the employee and the facility
is maintained, and the employee feels more valued, which can accelerate
the healing process.

Under Lewisville’s return-to-work program, the lost-time intervention
manager and other medical management staff begin to track employees
who are absent from work because of an injury or illness, whether or not it
was related to work. These employees are encouraged to return to work.
The lost-time intervention manager assists the medical management staff
to communicate with the doctor, the workers’ compensation office, and
the insurance office, as necessary. In 1995 alone, Lewisville’s
return-to-work activities resulted in 81 employees coming back to work. A
corporate safety official said that before implementing this program,
employees could easily become “lost in the system.” Once they are back at
work, employees’ conditions are monitored. Typically, injured employees
can be accommodated within their home work area on a restricted basis.
Several things have been done to facilitate these placements, including
developing a database of available jobs for workers on restriction and
creating a special account that covers the payroll costs of employees on
light duty (so the costs are not charged to that home work area’s budget).
If the limitations are permanent and prohibit the employee from
performing essential job functions with reasonable accommodation, the
employee is referred to the TI placement center for job search and other
placement assistance. Since 1995, a total of only four employees from the
several facilities composing the Systems Group have been transferred to
TI’s placement center because they could not be accommodated.




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                         Systems and Electronics Group
                         Headquarters, Lewisville, Texas




                         Corporate safety and health officials at TI strongly believed in the success
Results and Issues       of Lewisville’s ergonomics program, citing the reductions in injuries,
Related to Program       illnesses, and associated costs. In fact, because the program has already
Performance              achieved major reductions in injuries and illnesses, officials have now set
                         their sights on improving productivity and other performance-related
                         goals. Officials said Lewisville has also begun to measure its progress in
                         implementing particular initiatives and awards bonuses to members of the
                         ergonomics team—which can total $300 to $500 a person—on the basis of
                         progress achieved. For example, the facility uses a “productivity matrix,”
                         which assigns points on the basis of the accomplishment of particular
                         tasks for individual ergonomic projects, to assess its progress on its
                         administrative workstation adjustment campaign. Lewisville also tracks
                         the progress toward other targets, such as implementing at least 10 special
                         projects (“ERGO Days” was one of these), developing an action plan to
                         respond to the corporationwide safety audit within 5 days, and providing 1
                         hour of awareness training to 90 percent of the employees at the facility.
                         Using the productivity matrix, Lewisville compares its performance with
                         that of other facilities across TI and other companies participating in the
                         North Texas Ergonomics Consortium.

                         Corporate safety officials said that TI is probably in a better position than
                         most companies to measure its progress in reducing MSDs because it is a
                         “data-rich” company. Nonetheless, officials mentioned several factors that
                         affected their ability to measure program performance.


Reductions in Workers’   Workers’ compensation data provide evidence that the ergonomic efforts
Compensation Costs       at Lewisville are helping to reduce costs associated with MSDs. To capture
                         MSDs, Lewisville tracks “repetitive motion” and “body stress.” “Body stress”
Associated With MSDs
                         includes all strains and sprains and actually represents two categories
                         from the workers’ compensation database: “strains and sprains associated
                         with manual material handling” and “all other strains and sprains.” As
                         figure VII.1 shows, Lewisville achieved a 91-percent reduction in workers’
                         compensation costs for MSDs—from $2.6 million in 199196 to $224,000 in
                         1996. Additionally, the average cost for each MSD claim declined from
                         $21,946 in 1991 to $5,322 in 1996 (see fig. 3).




                         96
                          As more fully discussed in app. I, we attempted to present data for the year before the program’s full
                         implementation through 1996 for each of the facilities. For Lewisville, since the program was fully
                         implemented in 1992, we present data beginning in 1991.



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                                      Systems and Electronics Group
                                      Headquarters, Lewisville, Texas




Figure VII.1: Workers’ Compensation
Costs for MSDs at the TI Facility,    3000   Total Dollars for MSD Claims (in Thousands)
1991-96
                                             2590
                                      2500

                                                       2075
                                      2000                                 1957



                                                                 1481
                                      1500



                                      1000



                                       500                                            437

                                                                                              224


                                         0

                                               1991     1992      1993      1994       1995    1996
                                               Calendar Year



                                      Source: TI’s workers’ compensation database.




                                      Corporate officials said that increased awareness of ergonomics can lead
                                      to higher reporting of MSDs and, consequently, higher workers’
                                      compensation claims and costs. The officials said the high cost of MSDs in
                                      1991 can be attributed to the efforts the facility made to increase
                                      awareness in the late 1980s; similarly, the spike in 1994 can be attributed
                                      to heavy awareness training in the early 1990s, as well as a notification
                                      sent to all employees in 1993 of a possible program shutdown due to
                                      cutbacks in federal contracts (the shutdown was ultimately averted).
                                      Officials said employees are more likely to report injuries before a
                                      shutdown in order that they might collect workers’ compensation benefits
                                      should they be laid off.

                                      Officials also said they could not estimate total program costs or
                                      determine whether the reductions in MSD costs and other outcomes
                                      exceeded program expenditures. A facility official said it would be difficult
                                      to distinguish between those investments made for ergonomic reasons and
                                      those made for other purposes, such as to enhance productivity.




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                             Systems and Electronics Group
                             Headquarters, Lewisville, Texas




Reductions in Injuries and   Trends in overall injuries and illnesses reported in the OSHA 200 log are
Illnesses According to the   important because MSDs account for a significant portion of all injuries and
OSHA 200 Log                 illnesses at our case study facilities and because these data are what OSHA
                             looks at when inspecting a facility. Furthermore, OSHA 200 data are key to
                             how TI measures safety and health performance. In fact, using OSHA 200
                             data, Lewisville was able to demonstrate that it had achieved in 1996 its
                             yearly target of a 20-percent reduction in the overall incidence rate and the
                             lost or restricted workday rate. Meeting this goal contributed to the
                             corporationwide goal of eliminating all preventable occupational and
                             nonoccupational injuries and illnesses by the year 2005.

                             The facility’s incidence rate—the number of injuries and illnesses per 100
                             employees—for all injuries and illnesses recorded in its OSHA 200 log
                             declined from 5.5 in 1991 to 1.5 in 1996 (see fig. 4). The 1995 incidence rate
                             of about 2.1 was below the industry average of 3.8 for other manufacturers
                             of semiconductors and related devices in 1995, the most recent year for
                             which these data are available. Additionally, between 1991 and 1996,
                             Lewisville reduced the number of lost and restricted days for every 100
                             employees by 66 days and 15 days, respectively (see fig. 2).

                             While TI relies on OSHA 200 log data to track corporate performance in
                             safety and health, facility officials said it is important that the right OSHA
                             data be tracked. For example, officials said it is more meaningful to track
                             whether or not an injury or illness involved any lost or restricted days in
                             the first place than to track the actual number of lost and restricted days.97



Improvements in              Corporate and facility officials told us that, since Lewisville has already
Productivity, Quality, and   achieved major reductions in injury and illness rates, the facility is looking
Morale                       for new ways to measure progress made in productivity. However, they
                             also said they are just beginning to consider how productivity gains
                             through ergonomic improvements might be documented.98 These officials
                             believe that productivity gains will be more difficult to demonstrate than
                             injury and illness reduction, because most of the “low-hanging fruit” (that


                             97
                              This explains why the lost and restricted day case rates are not tracked at TI facilities. The site safety
                             engineer said the numbers of lost and restricted days were not as meaningful: They do not directly
                             correlate with the severity of the injury or illness because workers’ compensation laws can make it
                             difficult to bring employees back to work once they are out.
                             98
                               TI is also piloting “nonoccupational” safety and health projects to reduce injuries and illnesses
                             caused by activities employees do off the job. Corporate safety officials believe that these injuries and
                             illnesses contribute to significant productivity losses.



                             Page 133                                   GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix VII
The Ergonomics Program at TI, Defense
Systems and Electronics Group
Headquarters, Lewisville, Texas




is, problem jobs that are easier to identify and control) has already been
addressed at Lewisville.99

Currently, Lewisville is piloting productivity studies. For example, the
ergonomics team will be examining production bottlenecks to which
ergonomic hazards might be contributing. The team refers to these efforts
as its Continuous Flow Manufacturing Program. Recent efforts to improve
hand tools are part of this initiative. In addition, the Systems Group
Ergonomics Council recommended that Lewisville and other Systems
Group facilities and their respective ergonomics teams begin to compare
the productivity of operations at workstations that have adjustable-height
equipment with the productivity of operations at workstations that do not
have this equipment.100 Productivity changes will be measured in terms of
cycle time, output, and ergonomic gains. In addition, to document any
productivity changes, the ergonomics specialist plans to videotape these
jobs before and after the introduction of the adjustable-height
workstations.

Evidence regarding morale improvement was largely anecdotal. However,
corporate and facility staff emphasized that the ergonomics efforts at TI
were consistent with quality management principles and that employee
participation and empowerment are key to employee satisfaction. Medical
management staff said that medical management and return-to-work
efforts have benefited morale because they help demonstrate to
employees that they are valued.




99
  Another factor that makes productivity difficult to track, according to the team leader, is that,
because of its varied product line, TI tracks on-time delivery to contract and not to units produced per
hour per day. In addition, absenteeism is not a very useful measure, since TI offers employees a special
time-off policy.
100
   By installing an electric motor on workstation tables that were already being used at Lewisville, the
facility made its own adjustable-height workstations without having to purchase new ones. Part of the
table was also cut out so the employee could get closer to the microscope and other tools and
materials on the table.



Page 134                                  GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix VIII

Comments From the Department of Labor




                Page 135   GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix VIII
Comments From the Department of Labor




Page 136                        GAO/HEHS-97-163 Private Sector Ergonomics Programs
Appendix IX

GAO Contacts and Acknowledgments


                  Charles Jeszeck, Assistant Director, (202) 512-7036
GAO Contacts      Lori Rectanus, Project Manager, (202) 512-9847
                  Jackie Baker Werth, Senior Evaluator, (415) 904-2000


                  Other significant contributors to this report included Robert Crystal,
Staff             Senior Attorney, who reviewed the legal implications of our findings;
Acknowledgments   Benjamin Ross, Evaluator, who obtained information from state-operated
                  programs on efforts to encourage employers to reduce MSDs; George
                  Erhart, Senior Evaluator, who helped conduct and analyze the results of
                  the case studies; Ann McDermott, who developed the graphics used in this
                  report; Nancy Crothers, who edited and processed this report; and Bill
                  Tacy, Special Assistant to the Director, Office of Security and Safety, and
                  Joe Kile, Supervisory Economist, who contributed valuable comments and
                  feedback during the planning and implementation of this review.




(205330)          Page 137                      GAO/HEHS-97-163 Private Sector Ergonomics Programs
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