Worker Protection: Private Sector Ergonomics Programs Yield Positive
Results (Letter Report, 08/27/97, GAO/HEHS-97-163).

Pursuant to a congressional request, GAO provided information on
ergonomics programs to reduce work-related musculoskeletal disorders
(MSDs), focusing on: (1) the core elements of effective ergonomics
programs and how these elements are operationalized at the facility
level; (2) whether these programs have proven beneficial to the
employers and employees that have implemented them; and (3) the
implications of these employers' experiences for other employers and the
Occupational Safety and Health Administration (OSHA).

GAO noted that: (1) experts, research literature, and officials at GAO's
case study facilities 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: (a)
management commitment; (b) employee involvement; (c) identification of
problem jobs; (d) development of solutions (that is, controls) for
problem jobs; (e) training and education for employees; and (f)
appropriate medical management; (2) 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; (3) this
variety typically resulted from factors such as differences in the
facilities' industries and product line, corporate culture, and
experiences during the programs' evolution; (4) 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; (5) controls did not
typically require significant investment or resources and did not
drastically change the job or operation; (6) officials at all the
facilities GAO visited believed their ergonomics programs yielded
benefits, including reductions in workers' compensation costs associated
with MSDs; (7) 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; (8) facility officials also reported
improved worker morale, productivity, and product quality, although
evidence of this was often anecdotal; (9) 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; (10) GAO's 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; and
(11) federal and state-operated OSHA programs have undertaken a number
of initiatives that can provide 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.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  HEHS-97-163
     TITLE:  Worker Protection: Private Sector Ergonomics Programs Yield 
             Positive Results
      DATE:  08/27/97
   SUBJECT:  Human factors engineering
             Workers compensation
             Occupational health/safety programs
             Working conditions
             Occupational safety
             Employee medical benefits
             Health care cost control
             Safety standards
             Occupational health standards
             Accident prevention
IDENTIFIER:  OSHA Ergonomics Programs
             North Carolina
             Oregon
             California
             Maine
             
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Cover
================================================================ COVER


Report to Congressional Requesters

August 1997

WORKER PROTECTION - PRIVATE SECTOR
ERGONOMICS PROGRAMS YIELD POSITIVE
RESULTS

GAO/HEHS-97-163

Private Sector Ergonomics Programs

(205330)


Abbreviations
=============================================================== ABBREV

  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

Letter
=============================================================== LETTER


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 Administration\1 (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. 

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. 



                                Table 1
                
                 Employers and Facilities Selected for
                              Case Studies

                           Facility and   Product or          Staffing
Employer                   location       service                level
-------------------------  -------------  -------------  -------------
American Express                          Financial              5,300
Financial Advisors, Inc.   Headquarters;  planning and
                           Minneapolis,   other
                           Minnesota      investment
                                          services

AMP Incorporated           Electronic     Electronic               300
                           connectors     connection
                           manufacturing  devices
                           facility;      production
                           Tower City,
                           Pennsylvania

Navistar International     Truck          Heavy-and              4,000
Transportation             assembly       medium-duty
Corporation\a              facility;      truck
                           Springfield,   assembly
                           Ohio

Sisters of Charity Health  St. Mary's     Medical and              780
System                     Regional       nursing home
                           Medical        care
                           Center and
                           St.
                           Marguerite
                           d'Youville
                           Pavilion;\b
                           Lewiston,
                           Maine

Texas Instruments          Defense        Radar,                 2,800
                           systems and    navigation,
                           electronics    and missile
                           manufacturing  guidance
                           facility;      system
                           Lewisville,    assembly
                           Texas
----------------------------------------------------------------------
\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 programs\4 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. 


--------------------
\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. 

\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. 

\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. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

Experts, research literature, and officials at our case study
facilities 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 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. 


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


   BACKGROUND
------------------------------------------------------------ Letter :2

MSDs as a workplace concern have received increased attention over
the 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 illnesses\7 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 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 standard\10 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 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 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. 


--------------------
\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. 

\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. 

\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. 

\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. 


   AN EFFECTIVE PROGRAM INCLUDES A
   CORE SET OF ELEMENTS
------------------------------------------------------------ Letter :3

Experts, available literature, and officials at our case study
facilities generally agreed that, to be effective, an ergonomics
program should include a core set of elements or provisions to ensure
management 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. 


--------------------
\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. 


      MANAGEMENT COMMITMENT
---------------------------------------------------------- Letter :3.1

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
---------------------------------------------------------- Letter :3.2

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

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


--------------------
\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. 


      IDENTIFICATION OF PROBLEM
      JOBS
---------------------------------------------------------- Letter :3.3

A necessary component of any ergonomics program is the gathering of
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
      CONTROLS FOR PROBLEM JOBS
---------------------------------------------------------- Letter :3.4

The first step in eliminating the hazard is to analyze the job or job
task to identify the ergonomic hazards present in the job.  Once
ergonomic 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 controls\21 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 to recognize ergonomic
     hazards, and providing instruction in work practices that can
     ease the task demands or burden.\22


--------------------
\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. 

\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. 


      TRAINING AND EDUCATION
---------------------------------------------------------- Letter :3.5

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
---------------------------------------------------------- Letter :3.6

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 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
      ENCOURAGE EMPLOYERS TO
      IMPLEMENT THESE CORE
      ELEMENTS
---------------------------------------------------------- Letter :3.7

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.  For example, as a result of
inspections under the general duty clause, OSHA has entered into a
number 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 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 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. 


--------------------
\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. 

\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. 

\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. 


   FACILITIES HAVE IMPLEMENTED
   CORE ELEMENTS IN A VARIETY OF
   WAYS
------------------------------------------------------------ Letter :4

Each of the facilities we visited displayed all of the core elements
of an effective ergonomics program, but the facilities implemented
them in a variety of ways that reflected their unique
characteristics, such as their different industries and product
lines, corporate cultures, and experiences during program evolution. 
For example, although each facility 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 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 OTHER
      FACTORS HAVE INFLUENCED
      IMPLEMENTATION OF ELEMENTS
---------------------------------------------------------- Letter :4.1

All of the facilities' programs had evolved over time--often over
many years--and a number of factors were key to facilities' decisions
to take actions to reduce MSDs.\30 Primary among them was an interest
in reducing the workers' compensation costs associated with MSDs.\31
Additionally, the 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 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. 


--------------------
\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. 


      MANAGEMENT COMMITMENT IS
      DEMONSTRATED BY ASSIGNING
      STAFF TO BE RESPONSIBLE FOR
      THE ERGONOMICS PROGRAM
---------------------------------------------------------- Letter :4.2

All of the facilities had assigned staff to be specifically
responsible for the program and had provided them the resources,
time, and authority to operate the program on a daily basis.  Some of
the other indicators of management commitment were incorporating
ergonomic principles into corporationwide accountability mechanisms,
such as strategic goals or 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 RESPONSIBLE
         FOR ERGONOMICS
-------------------------------------------------------- Letter :4.2.1

The American Express Financial Advisors facility has an ergonomist
who 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 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
         ACCOUNTABILITY MECHANISMS
-------------------------------------------------------- Letter :4.2.2

The Texas Instruments facility works toward a corporationwide
strategic 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. 


--------------------
\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. 


         INTEGRATING ERGONOMIC
         PRINCIPLES INTO EQUIPMENT
         DESIGN
-------------------------------------------------------- Letter :4.2.3

At the Sisters of Charity facility, the on-site occupational health
clinic must approve any new construction to ensure that new work
areas are designed 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 THE PROGRAM
-------------------------------------------------------- Letter :4.2.4

At the AMP and Texas Instruments facilities, most of the suggestions
for 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. 


--------------------
\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. 


         ENSURING THAT MIDDLE
         MANAGEMENT SUPPORT IS
         SUSTAINED
-------------------------------------------------------- Letter :4.2.5

The Texas Instruments facility's Site Safety Quality Improvement Team
(QIT), which is composed of program managers, provides overall focus
and 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 how ergonomically related losses affected the
bottom line by discussing the costs of these injuries and their
impact on productivity. 


      EMPLOYEE INVOLVEMENT
      DEMONSTRATED THROUGH TEAMS,
      DIRECT EMPLOYEE ACCESS TO
      ERGONOMIC SERVICES
---------------------------------------------------------- Letter :4.3

Employee involvement at these facilities was often demonstrated
through the use of employee teams or committees charged with
identifying problem jobs and developing controls for them.  In
addition, employees had direct access to services; for example, some
facilities had procedures that ensured a job analysis was done upon
employee request.  The 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
-------------------------------------------------------- Letter :4.3.1

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 EMPLOYEES CAN DIRECTLY
         ACCESS ERGONOMIC SERVICES
-------------------------------------------------------- Letter :4.3.2

At the Navistar facility, any employee can request a job analysis by
filling out a one-page "Request for Ergonomic Study" form and passing
it along to 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
         CONDUCTING CAMPAIGNS
-------------------------------------------------------- Letter :4.3.3

American Express Financial Advisors' discomfort surveys help the
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
      PROCESS USED TO IDENTIFY
      PROBLEM JOBS
---------------------------------------------------------- Letter :4.4

All of the facilities in our review identified most of their problem
jobs on an "incidence basis," that is, from reports of MSDs or
employee discomfort or as the result of an employee request for
assistance.  The procedures 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 INCIDENCE BASIS
-------------------------------------------------------- Letter :4.4.1

All facilities had a system in place whereby any report of an MSD
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 PROACTIVE BASIS
-------------------------------------------------------- Letter :4.4.2

Because the Texas Instruments facility had already addressed many of
the 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
      ANALYZE PROBLEM JOBS AND
      DEVELOP CONTROLS
---------------------------------------------------------- Letter :4.5

All of the facilities in our review used a simple, fairly informal
procedure to analyze problem jobs, as compared with some of the more
complex 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 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
         OBSERVATION, INTERVIEWS,
         AND MEASUREMENTS
-------------------------------------------------------- Letter :4.5.1

The AMP facility uses a one-page "Ergonomic Evaluation Form" that is
tailored to the specific job and asks simple "yes/no" questions about
the 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 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.)


--------------------
\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. 


         DEVELOPING CONTROLS BY
         BRAINSTORMING AND USING
         IN-HOUSE RESOURCES
-------------------------------------------------------- Letter :4.5.2

Officials at all of the facilities said brainstorming was key to
developing controls.  At the Navistar facility, for example, the ad
hoc committee 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
         ITERATIVE PROCESS
-------------------------------------------------------- Letter :4.5.3

Ergonomics staff assess how well a control is working and, if
necessary, 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 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
         ENGINEERING CONTROLS
-------------------------------------------------------- Letter :4.5.4

The Navistar facility installed hoists to lift heavy fuel tanks and
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 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 TARGETED
      TO SPECIFIC GROUPS OF
      EMPLOYEES
---------------------------------------------------------- Letter :4.6

Some of the facilities provided general awareness training to all
employees, but this information was generally offered informally
through 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
-------------------------------------------------------- Letter :4.6.1

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
-------------------------------------------------------- Letter :4.6.2

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."


      ERGONOMICS PROGRAMS STRONGLY
      LINKED TO MEDICAL MANAGEMENT
      PROGRAMS
---------------------------------------------------------- Letter :4.7

The ergonomics programs at these facilities had strong links with the
medical management staff\35 in ways that were consistent with the
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. 


--------------------
\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. 


         ENCOURAGING EARLY
         REPORTING AND ENSURING
         PROMPT EVALUATION
-------------------------------------------------------- Letter :4.7.1

The Navistar facility has an on-site occupational health clinic and
medical management staff who are easily accessible to all employees
and who can 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 FAMILIAR WITH
         JOBS
-------------------------------------------------------- Letter :4.7.2

The American Express Financial Advisors facility has established a
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 DUTY TO RETURN
         EMPLOYEES TO WORK AND
         CONDUCTING FOLLOW-UP
-------------------------------------------------------- Letter :4.7.3

At the Texas Instruments facility, the lost time intervention manager
monitors health conditions of out-of-work employees and coordinates
with all other medical management staff to determine if the employee
can 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 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. 


   ERGONOMIC PROGRAMS BRING
   BENEFITS, ALTHOUGH MEASUREMENT
   PROBLEMS EXIST
------------------------------------------------------------ Letter :5

Officials at all the facilities we visited believed their ergonomics
programs brought benefits, including reductions in workers'
compensation costs associated with MSDs.  These facilities could also
show reductions in facilitywide overall injury and illness incidence
rates,\36 and in the number of days injured employees were away from
work, although some facilities reported an increase in the number of
days employees were on restricted 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. 


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


      FACILITIES HAVE REALIZED
      REDUCTION IN COSTS OF MSDS
---------------------------------------------------------- Letter :5.1

All five facilities experienced a reduction in total workers'
compensation costs for MSDs (see fig.  1).  Reductions are not
comparable across facilities, 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. 

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

   (See figure in printed
   edition.)

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 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. 

   Figure 2:  Change in Lost and
   Restricted Workdays for Case
   Study Facilities

   (See figure in printed
   edition.)

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 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
   Case Study Facilities

   (See figure in printed
   edition.)

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. 

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 Facilities

   (See figure in printed
   edition.)

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. 


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


      GAINS HAVE BEEN OBSERVED IN
      PRODUCTIVITY, QUALITY, AND
      EMPLOYEE MORALE
---------------------------------------------------------- Letter :5.2

Facility officials also reported improved employee productivity,
quality, and morale since they had implemented the programs, although
evidence 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. 


      MEASURING PROGRAM
      PERFORMANCE POSES MANY
      CHALLENGES
---------------------------------------------------------- Letter :5.3

Facility officials said they faced a number of challenges in
measuring the overall performance of their programs and tying
outcomes to the efforts 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 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). 
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. 


--------------------
\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. 

\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. 


      FACILITIES TRACK PROGRESS IN
      IMPLEMENTING THEIR PROGRAMS
---------------------------------------------------------- Letter :5.4

Perhaps because of these difficulties in tying outcomes to program
efforts, facility officials found it useful to track the actions
taken to implement the 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. 


   CASE STUDY EXPERIENCES
   HIGHLIGHT EMPLOYERS' SUCCESS IN
   REDUCING MSDS
------------------------------------------------------------ Letter :6

These private sector experiences highlight that employers can achieve
positive results through simple, informal, site-specific efforts,
with a lower level of effort to identify and analyze problem jobs
than that generally reflected in the safety and health literature or
in OSHA's draft ergonomics standard.  These experiences suggest that
OSHA may need to provide flexibility to employers to customize their
programs under a specified framework for a worksite ergonomics
program and give them some 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
      IMPLEMENTATION AND LOWER
      LEVEL OF EFFORT CAN PRODUCE
      RESULTS
---------------------------------------------------------- Letter :6.1

All of the facilities in our review implemented the core elements of
effective ergonomics programs.  In other words, each of the
facility's programs included all of the elements highlighted by
literature and experts as necessary for an effective program. 
However, the facilities often 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
      ABSENCE OF STANDARD PROVIDE
      EMPLOYERS FLEXIBILITY
---------------------------------------------------------- Letter :6.2

In the absence of a standard specifically for MSDs, federal and
state-operated OSHA programs have limited authority to take action
against employers for ergonomic hazards, which has resulted in a
variety of strategies and approaches to foster employer awareness and
action to 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 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 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.  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


--------------------
\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. 

\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. 

\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. 


      LACK OF ADEQUATE INFORMATION
      COMPLICATES PROGRAM
      OPERATIONS AND MEASUREMENT
---------------------------------------------------------- Letter :6.3

At the facilities we visited, the impetus for developing an
ergonomics program was often an initial concern with excessive
workers' compensation costs.  At these facilities, this concern led
to an examination of workers' compensation and other data that
ultimately identified MSDs as 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. 


--------------------
\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. 


   CONCLUSIONS
------------------------------------------------------------ Letter :7

Currently, billions of dollars are spent by private sector employers
on 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. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :8

We obtained comments on a draft of this report from the Department of
Labor's Acting Assistant Secretary for Occupational Safety and
Health.  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 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


OBJECTIVES, SCOPE, AND METHODOLOGY
=========================================================== Appendix I

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 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. 


   SELECTION PROCESS USED FOR CASE
   STUDY FACILITIES
--------------------------------------------------------- Appendix I:1

Through interviews, a review of the literature, and requesting
nominations using trade association bulletin boards, we identified
132 employers that experts believed had made gains in reducing
workers' compensation costs 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 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. 


   REVIEW OF CASE STUDY RESULTS
--------------------------------------------------------- Appendix I:2

Our work is based predominantly on case studies of five employers
that believe their programs are effective at reducing workers'
compensation 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 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
United Auto Workers
United Food and Commercial Workers
USAA


   ISSUES TO CONSIDER REGARDING
   DATA FOR CASE STUDY EMPLOYERS
--------------------------------------------------------- Appendix I:3

Significant differences in the data provided by the case study
facilities make comparison among the facilities inappropriate.  For
example, data presented for each of the facilities vary depending
upon when the facility 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. 



                               Table I.1
                
                 Years Facilities' Programs Were Fully
                   Implemented and Years of Data Used

                                Year program fully
Case study facility                    implemented  Years of data used
------------------------------  ------------------  ------------------
AEFA                                          1993           1992-96\a
AMP                                           1993           1993-96\b
Navistar                                      1994             1993-96
SOCHS                                         1994           1994-96\c
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. 



                               Table I.2
                
                  Categories of Injuries and Illnesses
                Tracked as MSDs at Case Study Facilities

Case study
facility            Injuries and illnesses tracked
------------------  --------------------------------------------------
AEFA                Computer, mouse, and other repetitive motion
                    injuries\a

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 injuries\b

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. 


PROFILES OF SELECTED PROBLEM JOBS
AT THE CASE STUDY FACILITIES
========================================================== Appendix II



   (See figure in printed
   edition.)



   (See figure in printed
   edition.)



   (See figure in printed
   edition.)


THE ERGONOMICS PROGRAM AT AEFA
HEADQUARTERS, MINNEAPOLIS,
MINNESOTA
========================================================= Appendix III


   BACKGROUND
------------------------------------------------------- Appendix III:1

Formerly Investors Diversified Services, Inc., American Express
Financial 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. 


   INITIATING THE ERGONOMICS
   PROGRAM AT AEFA
------------------------------------------------------- Appendix III:2

The current ergonomics program at AEFA was fully implemented in 1993,
when a full-time ergonomist and other ergonomics staff were hired,
training was provided to all employees, and an effort was made to
infuse 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. 


   STRUCTURE AND CORE ELEMENTS OF
   THE PROGRAM AT AEFA
------------------------------------------------------- Appendix III:3

AEFA's ergonomics program is led by the ergonomics staff (the
ergonomist, the ergonomics specialist, and a half-time administrative
assistant) and is currently located in the support services
department.  Various other 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
----------------------------------------------------- Appendix III:3.1

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 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
----------------------------------------------------- Appendix III:3.2

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 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
      JOBS
----------------------------------------------------- Appendix III:3.3

AEFA identified problem jobs primarily on an incidence basis.  In
other 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. 

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. 


--------------------
\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. 


      ANALYZING PROBLEM JOBS AND
      DEVELOPING CONTROLS
----------------------------------------------------- Appendix III:3.4

AEFA officials emphasized that, in most cases, they do not do job
analysis 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
--------------------------------------------------- Appendix III:3.4.1

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. 

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
         CONTROLS
--------------------------------------------------- Appendix III:3.4.2

AEFA officials described their process for developing controls for
problem 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 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
--------------------------------------------------- Appendix III:3.4.3

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
surfaces\54 ).  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. 


      TRAINING AND EDUCATION
----------------------------------------------------- Appendix III:3.5

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
----------------------------------------------------- Appendix III:3.6

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. 

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. 


--------------------
\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. 


   RESULTS AND ISSUES RELATED TO
   PROGRAM PERFORMANCE
------------------------------------------------------- Appendix III:4

AEFA officials said they are pleased with the results of the program,
which they believed has helped reduce workers' compensation costs for
MSDs and improve employee productivity and morale.  However, they
raised several 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'
      COMPENSATION COSTS
      ASSOCIATED WITH MSDS
----------------------------------------------------- Appendix III:4.1

As shown in figure III.1, AEFA reduced its costs for MSD workers'
compensation claims by about 80 percent (from about $484,000 to about
$98,000) between 1992\57 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. 

   Figure III.1:  Workers'
   Compensation Costs for MSDs at
   AEFA, 1992-96

   (See figure in printed
   edition.)

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 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. 


--------------------
\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. 


      REDUCTIONS IN INJURIES AND
      ILLNESSES ACCORDING TO THE
      OSHA 200 LOG
----------------------------------------------------- Appendix III:4.2

As a financial institution, AEFA is not required to maintain the OSHA
200 log.  However, AEFA's safety department does keep the OSHA 200
log voluntarily 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. 


--------------------
\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. 


      IMPROVEMENTS IN
      PRODUCTIVITY, QUALITY, AND
      MORALE
----------------------------------------------------- Appendix III:4.3

Facility management officials said the ergonomics program has
contributed to increased productivity and quality of work as well as
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 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. 


--------------------
\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. 


THE ERGONOMICS PROGRAM AT AMP,
ELECTRONIC CONNECTORS
MANUFACTURING FACILITY, TOWER
CITY, PENNSYLVANIA
========================================================== Appendix IV


   BACKGROUND
-------------------------------------------------------- Appendix IV:1

AMP Incorporated, which began operation in 1941, is a manufacturer of
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 groups\61 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. 


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


   INITIATING THE ERGONOMICS
   PROGRAM AT TOWER CITY
-------------------------------------------------------- Appendix IV:2

The ergonomics program at Tower City was fully implemented as of
1993, when the facility formed an ergonomics team.  The team was
formed in response to the global safety department's promotion of
ergonomics 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 forming teams of employees to get them more
involved in production activities and to identify production
problems. 


   STRUCTURE AND CORE ELEMENTS OF
   THE PROGRAM AT TOWER CITY
-------------------------------------------------------- Appendix IV:3

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


--------------------
\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. 


      MANAGEMENT COMMITMENT
------------------------------------------------------ Appendix IV:3.1

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
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
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
------------------------------------------------------ Appendix IV:3.2

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
      JOBS
------------------------------------------------------ Appendix IV:3.3

There are several ways in which the ergonomics team learns that a job
might be a problem.  The following methods for identifying problem
jobs 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" incident\63 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. 


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


      ANALYZING PROBLEM JOBS AND
      DEVELOPING CONTROLS
------------------------------------------------------ Appendix IV:3.4

Facility officials described their process for analyzing problem jobs
and 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 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
---------------------------------------------------- Appendix IV:3.4.1

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 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
         CONTROLS
---------------------------------------------------- Appendix IV:3.4.2

The controls themselves are developed informally, through
"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
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 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
---------------------------------------------------- Appendix IV:3.4.3

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
------------------------------------------------------ Appendix IV:3.5

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. 

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
------------------------------------------------------ Appendix IV:3.6

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 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


--------------------
\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. 


   RESULTS AND ISSUES RELATED TO
   PROGRAM PERFORMANCE
-------------------------------------------------------- Appendix IV:4

AMP officials said they were generally satisfied with the results of
Tower City's ergonomics program, which has sought to improve worker
safety and health through reduced injury rates and lower workers'
compensation 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. 


      REDUCTIONS IN WORKERS'
      COMPENSATION COSTS
      ASSOCIATED WITH MSDS
------------------------------------------------------ Appendix IV:4.1

Workers' compensation data provide some evidence that the ergonomics
efforts at Tower City are helping to reduce costs associated with
MSDs.  To 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 1993\65 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, 1993-96

   (See figure in printed
   edition.)

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 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. 


--------------------
\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. 


      REDUCTIONS IN INJURIES AND
      ILLNESSES ACCORDING TO THE
      OSHA 200 LOG
------------------------------------------------------ Appendix IV:4.2

Trends in overall injuries and illnesses from the OSHA 200 log are
important because MSDs account for a significant portion of all
injuries and illnesses 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
      PRODUCTIVITY, QUALITY, AND
      MORALE
------------------------------------------------------ Appendix IV:4.3

Tower City has also established a linkage between ergonomic
investments and productivity or quality improvements.  By examining
production 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 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."


THE ERGONOMICS PROGRAM AT
NAVISTAR, SPRINGFIELD ASSEMBLY
FACILITY, SPRINGFIELD, OHIO
=========================================================== Appendix V


   BACKGROUND
--------------------------------------------------------- Appendix V:1

Navistar International Transportation Corp.  manufactures heavy- and
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 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. 


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


   INITIATING THE ERGONOMICS
   PROGRAM AT SPRINGFIELD
--------------------------------------------------------- Appendix V:2

The current ergonomics program at Springfield was fully implemented
in 1994 with the hiring of the current ergonomist.  However,
Springfield's program has evolved over a decade of experimenting with
a number of 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, 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. 


   STRUCTURE AND CORE ELEMENTS OF
   THE PROGRAM AT SPRINGFIELD
--------------------------------------------------------- Appendix V:3

Springfield's ergonomics program is led by a full-time ergonomist and
a local UAW representative (who works on ergonomics about 3 days a
week).  The ergonomist reports to the environmental safety and health
manager, who reports directly to the facility manager.  Other
departments are involved with the program, such as the workers'
compensation branch (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
------------------------------------------------------- Appendix V:3.1

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


--------------------
\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. 

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


      EMPLOYEE INVOLVEMENT
------------------------------------------------------- Appendix V:3.2

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; 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
      JOBS
------------------------------------------------------- Appendix V:3.3

Springfield identifies problem jobs primarily on an incidence basis. 
In 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 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 AND
      DEVELOPING CONTROLS
------------------------------------------------------- Appendix V:3.4

Springfield's process for analyzing jobs and developing controls was
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 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
----------------------------------------------------- Appendix V:3.4.1

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
         CONTROLS
----------------------------------------------------- Appendix V:3.4.2

Once the committee has finished analyzing the job, it follows an
informal 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 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 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
----------------------------------------------------- Appendix V:3.4.3

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 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
------------------------------------------------------- Appendix V:3.5

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
------------------------------------------------------- Appendix V:3.6

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, 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. 


   RESULTS AND ISSUES RELATED TO
   PROGRAM PERFORMANCE
--------------------------------------------------------- Appendix V:4

Navistar officials said they are generally satisfied with
Springfield's ergonomics program's contribution to improved worker
safety and health, reduced injury rates, and lower workers'
compensation costs.  Officials 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'
      COMPENSATION COSTS
      ASSOCIATED WITH MSDS
------------------------------------------------------- Appendix V:4.1

As shown in figure V.1, Springfield reduced its costs for workers'
compensation claims associated with MSDs\69 from almost $1.4 million
in 1993\70 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 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, 1993-96

   (See figure in printed
   edition.)

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. 

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. 


--------------------
\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. 


      REDUCTIONS IN INJURIES AND
      ILLNESSES ACCORDING TO THE
      OSHA 200 LOG
------------------------------------------------------- Appendix V:4.2

Navistar also uses the OSHA 200 log to assess its performance in
reducing injuries and illnesses on a facilitywide basis. 
Additionally, these data are 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
      PRODUCTIVITY, QUALITY, AND
      MORALE
------------------------------------------------------- Appendix V:4.3

Officials believed that, in many cases, ergonomic improvements had
contributed to productivity, quality, and morale improvements.  While
the 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. 

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. 


THE ERGONOMICS PROGRAM AT SOCHS,
LEWISTON, MAINE
========================================================== Appendix VI


   BACKGROUND
-------------------------------------------------------- Appendix VI:1

The Sisters of Charity Health System is a for-profit health care
provider 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. 


   INITIATING THE ERGONOMICS
   PROGRAM AT SOCHS
-------------------------------------------------------- Appendix VI:2

Officials told us the program was fully implemented in 1994 after
they had undertaken a number of efforts in response to OSHA's
September 1993 invitation to participate in the Maine 200 program. 
These efforts were 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. 


   STRUCTURE AND CORE ELEMENTS OF
   THE PROGRAM AT SOCHS
-------------------------------------------------------- Appendix VI:3

SOCHS' ergonomics program is led by several officials located in the
human resources department--the director of risk management and
safety, the safety coordinator, and the risk management coordinator. 
A doctor and an 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. 

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
------------------------------------------------------ Appendix VI:3.1

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" 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
------------------------------------------------------ Appendix VI:3.2

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. 


      IDENTIFICATION OF PROBLEM
      JOBS
------------------------------------------------------ Appendix VI:3.3

SOCHS identifies problem jobs primarily on an incidence basis.  In
other 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 place, WorkMed provides guidance on
appropriate workstation and equipment design and must certify that
design is ergonomic before final approval. 


--------------------
\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. 


      ANALYZING PROBLEM JOBS AND
      DEVELOPING CONTROLS
------------------------------------------------------ Appendix VI:3.4

SOCHS officials said the process it uses to analyze problem jobs is
simple.  In 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
---------------------------------------------------- Appendix VI:3.4.1

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 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. 


--------------------
\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. 


         PROCESS USED TO DEVELOP
         CONTROLS
---------------------------------------------------- Appendix VI:3.4.2

Once the WorkMed staff have completed the workstation evaluation,
they 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 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
---------------------------------------------------- Appendix VI:3.4.3

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 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
------------------------------------------------------ Appendix VI:3.5

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."

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. 


--------------------
\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. 


      MEDICAL MANAGEMENT
------------------------------------------------------ Appendix VI:3.6

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 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. 


--------------------
\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. 


   RESULTS AND ISSUES RELATED TO
   PROGRAM PERFORMANCE
-------------------------------------------------------- Appendix VI:4

SOCHS officials said they were generally satisfied with the results
of their program because of (1) the reductions in injuries and their
associated workers' compensation costs and (2) an improved safety and
health 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 be considered
when reviewing these results that often complicated their ability to
tie results directly to their efforts. 


--------------------
\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. 


      REDUCTIONS IN WORKERS'
      COMPENSATION COSTS
      ASSOCIATED WITH MSDS
------------------------------------------------------ Appendix VI:4.1

As figure VI.I shows, the medical center and nursing home together
reduced workers' compensation costs for MSDs by about 35 percent
between 1994 and 1996\84 (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). 

   Figure VI.1:  Workers'
   Compensation Costs for MSDs at
   SOCHS' Medical Center and
   Nursing Home, 1994-96

   (See figure in printed
   edition.)

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 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. 


--------------------
\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. 

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


      REDUCTIONS IN INJURIES AND
      ILLNESSES ACCORDING TO THE
      OSHA 200 LOG
------------------------------------------------------ Appendix VI:4.2

The OSHA 200 log data are instructive because they illustrate a
facility's 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 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). 

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. 


--------------------
\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. 

\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. 


      IMPROVEMENTS IN
      PRODUCTIVITY, QUALITY, AND
      MORALE
------------------------------------------------------ Appendix VI:4.3

SOCHS officials believed that their emphasis on ergonomics, and
safety and health in general, had contributed to an improved work
environment, but 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. 


THE ERGONOMICS PROGRAM AT TI,
DEFENSE SYSTEMS AND ELECTRONICS
GROUP HEADQUARTERS, LEWISVILLE,
TEXAS
========================================================= Appendix VII


   BACKGROUND
------------------------------------------------------- Appendix VII:1

Texas Instruments, which began operation in 1951, is a manufacturer
of 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's corporate 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 1992, when it had about 3,700 employees, and 1996, when
approximately 2,800 employees were employed at this facility. 


   INITIATING THE ERGONOMICS
   PROGRAM AT LEWISVILLE
------------------------------------------------------- Appendix VII:2

The ergonomics program at Lewisville was fully implemented in 1992,
the year after workers' compensation costs for MSDs exceeded $2
million, causing considerable alarm among facility management.  TI's
ergonomics 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.  In 1996, the ergonomics team
was reorganized to include a cross section of facility employees. 


   STRUCTURE AND CORE ELEMENTS OF
   THE PROGRAM AT LEWISVILLE
------------------------------------------------------- Appendix VII:3

The heart of the ergonomics program at Lewisville is its ergonomics
team, to which the full-time ergonomics specialist and the site
safety engineer provide support.  Other teams formed for broader
objectives within the 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
----------------------------------------------------- Appendix VII:3.1

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 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 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


--------------------
\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. 

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


      EMPLOYEE INVOLVEMENT
----------------------------------------------------- Appendix VII:3.2

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 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
      JOBS
----------------------------------------------------- Appendix VII:3.3

There are several ways in which the ergonomics team and the
ergonomics 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 "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. 


--------------------
\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. 

\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. 


      ANALYZING PROBLEM JOBS AND
      DEVELOPING CONTROLS
----------------------------------------------------- Appendix VII:3.4

Facility officials described analyzing problem jobs and developing
controls as generally an "informal" process.  The ergonomics
specialist referred to 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
--------------------------------------------------- Appendix VII:3.4.1

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 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
--------------------------------------------------- Appendix VII:3.4.2

Controls are typically developed informally by the ergonomics
specialist, 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. 

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. 

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
--------------------------------------------------- Appendix VII:3.4.3

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 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
----------------------------------------------------- Appendix VII:3.5

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 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 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. 


--------------------
\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. 

\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. 


      MEDICAL MANAGEMENT
----------------------------------------------------- Appendix VII:3.6

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
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. 


   RESULTS AND ISSUES RELATED TO
   PROGRAM PERFORMANCE
------------------------------------------------------- Appendix VII:4

Corporate safety and health officials at TI strongly believed in the
success of Lewisville's ergonomics program, citing the reductions in
injuries, illnesses, and associated costs.  In fact, because the
program has already 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'
      COMPENSATION COSTS
      ASSOCIATED WITH MSDS
----------------------------------------------------- Appendix VII:4.1

Workers' compensation data provide evidence that the ergonomic
efforts at Lewisville are helping to reduce costs associated with
MSDs.  To capture MSDs, Lewisville tracks "repetitive motion" and
"body stress." "Body stress" 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 1991\96 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). 

   Figure VII.1:  Workers'
   Compensation Costs for MSDs at
   the TI Facility, 1991-96

   (See figure in printed
   edition.)

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. 


--------------------
\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. 


      REDUCTIONS IN INJURIES AND
      ILLNESSES ACCORDING TO THE
      OSHA 200 LOG
----------------------------------------------------- Appendix VII:4.2

Trends in overall injuries and illnesses reported in the OSHA 200 log
are important because MSDs account for a significant portion of all
injuries and 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


--------------------
\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. 


      IMPROVEMENTS IN
      PRODUCTIVITY, QUALITY, AND
      MORALE
----------------------------------------------------- Appendix VII:4.3

Corporate and facility officials told us that, since Lewisville has
already achieved major reductions in injury and illness rates, the
facility is looking 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 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. 



(See figure in printed edition.)Appendix VIII

--------------------
\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. 

\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. 


COMMENTS FROM THE DEPARTMENT OF
LABOR
========================================================= Appendix VII



(See figure in printed edition.)


GAO CONTACTS AND ACKNOWLEDGMENTS
========================================================== Appendix IX

GAO CONTACTS

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

STAFF ACKNOWLEDGMENTS

Other significant contributors to this report included Robert
Crystal, Senior Attorney, who reviewed the legal implications of our
findings; 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. 

*** End of document. ***