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PMPA recently provided formal written testimony, additional supporting comments and an estimate of implementation costs at the recently held informal hearing at OSHA in Washington D.C. last week.
You are busy enough running your shop and serving customers, so we prepared comments  and went to Washington to represent the small manufacturing companies like yours about what we thought the proposed rules’ impact would be.
We had three broad themes:

  1. No safety or health outcome benefit for workers has been established;
  2. On line reporting will discourage recruitment of employees to manufacturing careers;
  3. Encourages employees not just employers to mask injuries and illnesses. An unexpected outcome due to changes to worker deductibles in their health insurance due to the Affordable Care Act may result in a spike of false ‘at work’ injuries being reported . from employees with non work related injuries who may balk at personally paying their new high deductibles for emergency care.

We provided formal comments prior to the meeting.
This YouTube Video captures my additional comments to the panel at the informal hearing: Link

And here is our back of the envelope calculation to disprove the agencies “$9” per small shop cost of implementing the proposed rule.

The Agency estimate of $9 to implement doesn't even  factor in reasonable time or wages.
The Agency estimate of $9 to implement doesn’t even factor in reasonable time or wages.

We remain puzzled why this administration would throw an obstacle like this to dissuade people from careers in manufacturing with the current job situation so dire, by providing numeric injury and illness rates publically without any context for understanding. So we tried to explain what we thought the impacts will be.

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