WASHINGTON (March 17, 2000)—The federal government´s proposed ergonomics standard could cost U.S. tire makers nearly $70,000 per employee to retrofit tire machines alone.
This is 70 times what the Occupational Safety and Health Administration projects the proposal will cost tire makers altogether, according to the Rubber Manufacturers Association.
For this and other reasons, the RMA blasted the ergonomics proposal in comments submitted to OSHA March 2.
"The rule would require employers to make costly changes when work `contributes´ to pain or discomfort, even if work was not the underlying cause and even if the musculoskeletal discomfort did not reflect actual injury or illness," stated the 57-page document signed by RMA President Donald B. Shea.
"The rule gives no intelligible direction on what particular workplace changes are needed, and indeed the world´s leading ergonomists repeatedly have failed to identify effective ergonomic measures," it said. "These requirements are so vague and open-ended that they will not pass constitutional scrutiny."
Symptoms the ergonomics rule is meant to allay—numbness, tingling, stiffness, pain and fatigue—are common to the entire population and have any number of causes, the RMA statement noted. But in writing the proposal, "the agency began with the premise that work is the principal cause of musculoskeletal discomfort and then looked for studies that agreed," it said.
OSHA relied excessively on a "biased" and "flawed" 1997 survey on musculoskeletal disorders from the National Institute of the Occupational Safety and Health, the RMA said. Even the NIOSH survey, it added, suggests psychological factors may be more important than actual physical injury in ergonomic complaints.
Along with favoring biased studies, the agency grossly underestimates the cost of compliance with the proposed rule, according to the association.
OSHA projects the ergonomics rule will cost employers $4.2 billion annually but yield annual benefits of $9.1 billion in improved productivity and savings in medical expenses. For tire manufacturers, the rule will cost about $965 per year to implement, according to the agency.
But the OSHA estimate is meaningless, the RMA said, because it "is based entirely on describing pre-selected control measures to three ergonomists and asking them what they believe the measures´ costs would be. There is absolutely no evidence that the measures described to the ergonomists were the ones that would actually be required by the rule."
The ergonomists also disagreed wildly about the costs of the control measures selected by OSHA, with one tripling or quadrupling the projections of another, the association said.
Two tire-maker members of the RMA made their own cost estimates apropos the ergonomics rule. One tire manufacturer determined that to make one tire-building machine compliant with the rule would cost $207,000, averaging to nearly $70,000 per employee. The second company figured that to bring into compliance a machine designed to make large off-road tires would cost $700,000 to $900,000.
"Even these estimates greatly understate the cost of the proposed rule for the rubber products industry because they describe only single changes to single machines," the association said.
Currently, OSHA is holding public hearings on the ergonomics proposal in Washington, with further hearings scheduled later this spring in Chicago and Portland, Oregon.
The RMA has requested the chance to testify publicly in Washington, but may not do so if the testimony of other organizations overlaps its own, according to Ann Wilson, RMA vice president of government affairs. ©