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STATEMENT OF PAUL H. APPELBLOM, Good afternoon. I am Paul H. Appelblom, President of Jatco, Inc., appearing today on behalf of the Society of the Plastics Industry, Inc. (which I will refer to as SPI). We greatly appreciate this opportunity to explain SPI's policy and views in the area of workplace ergonomics and will use our operations at Jatco to illustrate why we believe this is an area that requires tremendous flexibility and would greatly benefit from government-supported research and outreach but is not suited to command and control regulation. Given the brief period allowed for testimony, I will attempt to focus on those aspects of our statement which I believe tell an important story and ask that my entire written statement be entered into the record. Founded in 1937, The Society of the Plastics Industry, Inc. is a tax-exempt trade association representing one of the largest manufacturing industries in the United States. SPI has approximately 1,500 members representing the entire plastics industry supply chain, including processors, machinery and equipment manufacturers and raw material suppliers. The U.S. plastics industry employs approximately 1.5 million workers and annually produces goods with an approximate aggregate value of $304 billion. The plastics industry has a tremendous investment and employee base in California. As of 1999, California's plastics industry had over 137,000 employees working in over 2,600 companies. As you may deduce from these numbers, the plastics industry is highly entrepreneurial, with a large percentage of our industry being smaller companies. Jatco is a 25 year old custom plastic injection molding company located in Union City, California., that manufactures a broad variety of injection-molded products. We are a job shop. We employ between150 to 200 employees, of which approximately 2/3 are in manufacturing positions. Our plant operates around the clock--24 hours a day, 7 days a week. In simple terms, plastic injection molding is a process in which solid plastic pellets are melted and the molten plastic is then injected into a steel mold under extremely high pressures to form the desired final shape of the item (which might be anything from a plastic spoon to the bumper of a car). Depending on the nature of the product and the requirements of the process, the time per cycle of the injection molding machine may vary from 5 seconds to 2 minutes. Some molded parts are removed from the mold robotically and some are removed by hand. Subsequently, many operations can be performed on plastic parts after removal from the mold such as assembly, decorating, trimming of excess material and packaging of the final product. Due to the nature of our business, we never make the same products on all of our machines two days in a row. We frequently change out molds and retool various production lines several times a day and sometimes several times within a shift. The products we manufacture come in virtually all shapes and sizes, which minimizes the viability of using fully automated equipment. This is fairly typical of our industry. All of this means that it is critical to our business that we have a trained, motivated and flexible workforce with the skills that match the needs of our business. Our employees truly are our most valuable assets. SPI believes ergonomic principles are beneficial to both employers and employees in terms of productivity, worker comfort and worker safety, and should be a part of an employer's comprehensive health and safety program. Application of these principles should be based on sound science and accepted risk management practices. Any initiative that addresses ergonomics, whether regulatory-driven or industry-driven, should provide each facility with the flexibility to develop and implement a process for managing workplace ergonomic hazards and musculoskeletal disorders tailored to the operations, activities, needs, people and culture at that facility. Our firm, Jatco, wholeheartedly agrees with these principles and we believe our operations demonstrate their real world application. Like many smaller employers, we cannot justify the expense of a full-time safety manager who could provide us with all of the expertise needed to ensure the safety of our operations. Instead our General Manager also wears the hat of site safety manager, and we have retained the services of an outside consulting firm to assist us in developing, implementing and auditing the components of our safety program. For us, this arrangement has worked extremely well. We are extremely fortunate that our General Manager is an industrial engineer with several years of higher education in ergonomics and significant experience in the automobile industry. Under the direction of our General Manager, ergonomics efforts in our company reflect the common sense principle that the most comfortable and easiest way to perform a job will be the most productive and will minimize the potential for work-related musculoskeletal disorders-however you choose to define them. Based on this principle, we follow the following general qualitative guidelines:
Although our General Manager is familiar with the various numerical formulas addressing ergonomics issues (e.g., NIOSH Lifting Equation), he does not use them or advocate their use. Nor does he attempt to formally assess and quantify risk factors, use action triggers, or reduce exposures to risk factors below a quantified level. Nor do we get involved in formal training programs that attempt to convert every supervisor into an ergonomist. When we interview job applicants, we do our best to explain the nature and demands of the job and our operations. We explain that, due to the broad range of our product lines and the nature of our manufacturing operations, the applicant cannot do just one thing but must be comfortable with a highly flexible work environment. We explain that we rotate personnel so that they develop their skills, remain motivated and avoid over-exposure to repetitive motions of the same muscle groups. A new hire is brought in for a six month probationary period to give us time to confirm that they have the necessary skills and fit in with our operating philosophy. During that time period, we have the opportunity to identify the individual's skills and what they do best. Through this approach, we have found that approximately 70% of the tasks in our plant can be safely and efficiently performed by almost our entire manufacturing workforce, that approximately 15% of the tasks require fine detail motor skills, and that approximate 15% require substantial brute force. As we better identify an employee's skills and what they like and do best, we become more effective in matching job assignments and rotations to what they are most comfortable with, including a number of workers with disabilities. We teach and emphasize to our employees that they should perform a task in the way that is most comfortable and easiest for them. We explain that if a person performs a task in the way that is most comfortable and easiest for them, they will be productive and they will not experience a work-related musculoskeletal disorder. I do not mean to suggest that a worker has complete freedom to work at whatever pace is most comfortable. We have standards of performance for every job assignment. They are developed through what we believe to be a very fair and efficient process that is non-quantitative and not formally documented. First, the job assignment is reviewed and performed by our General Manager and one other manager to determine the most comfortable and easiest way to perform it, and any appropriate adjustments are made. Second, we have the job performed by several employees who we believe represent the group of workers with the skill set suitable for that job. We then establish the performance standard for that job based on what they find to be a comfortable pace for the various components of that job. We estimate that only a very small percentage of our workers cannot meet our performance standards. Jatco operates under the philosophy that our door is always open to our employees' suggestions and concerns. Our organization is small enough that our employees know everybody they work with personally. We tell our employees that if your job is uncomfortable, come tell us about it and we will work with you to identify the problem; don't wait until it becomes something serious that would require medical attention or time off from work. There is an outstanding atmosphere of trust and mutual cooperation in dealing with ergonomics issues. Under this proactive approach, we have been very successful in making adjustments that eliminate the discomfort from the job. But it is critical to point out that this entire approach is only successful in a working environment based on trust, responsible behavior and mutual benefit, and not one based on a one-size-fits -all government mandate. We are voluntarily responding to symptoms that are not serious enough to justify medical attention, but which we believe are being communicated to us in good faith. By assigning and shifting people to jobs based on their skill sets, we avoid wasting resources trying to fix jobs that are not "problem jobs" as that term was used under the rescinded OSHA standard. For obvious reasons, a government mandate that an employer do what we are doing--respond to every symptom report and assign people to jobs based on their skill sets (much less document the report, our response and the remedial action)-- is totally unworkable. Furthermore, our approach will not work in those establishments where the labor-management structure does not allow for the tremendous level of flexibility we have at our facility. In light of the manner in which we deal with ergonomic issues, we hope you will understand why we believe the rescinded rule would have undermined our workers compensation and managed care systems, labor-management relations, our efforts to ensure workplace safety in a balanced and practical manner, our productivity and global competitiveness, and our quality of life. The Most Useful and Cost-effective Types of Government Involvement As demonstrated by our ergonomics efforts, we believe there is a direct link between ergonomics and workplace safety. It is also clear that the current science does not provide a basis for the adoption of an OSHA ergonomics standard that would satisfy the six framework principles established by the Secretary. This is one of the most complex issues in the area of occupational safety and health. Most small employers are not fortunate to have as their General Manager an industrial engineer with formal ergonomics training and extensive practical experience. Given the linkage between ergonomics and workplace safety, we believe OSHA has a major role in this area, which at the present time could best be advanced by supporting, in close cooperation with the affected stakeholders
We believe those guidelines or best practices should focus on those tasks or industries where the risks of ergonomic injuries appear to be the greatest. This type of effort would have the greatest potential for success if OSHA were to establish and rely on a separate, carefully balanced special advisory committee for each such industry. This approach is consistent with the NAS report on ergonomic injuries, which noted that "no single strategy is or will be effective for all types of industry." In shifting from the consideration of government initiatives involving research and outreach to the consideration of guidelines or a mandatory standard, far greater care must be given to what the science supports and the law allows. And far greater concern must be given to avoiding programs that would undermine what is already working extremely well at places like Jatco. Thank you for your attention. I will do my best to answer any questions you may have.
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 © Copyright 2001 The Society of the Plastics Industry.
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