February 25, 2000

OSHA Docket Office
Docket No. S-777
Occupational Safety and Health Administration
U.S. Department of Labor
Room N-2625
Washington, DC 20210

Fax: 202/693-1648

Re: Comments on OSHA’s Proposed Ergonomics Program Standard

Dear Sir or Madam:

The IPC- Association Connecting Electronics Industries- is submitting these comments on the U.S. Occupational Safety and Health Administration’s proposed ergonomics standard (64 Fed. Reg. 65768). If implemented, the extensive proposal on ergonomic disorders would have a drastic impact on almost every business establishment throughout the country, especially small businesses of which constitutes the majority of our member companies. The proposal lacks scientific basis and would impose a huge financial burden on our member companies by redirecting important resources and attention away from issues that have a more substantial impact on employee health and safety. IPC supports OSHA’s emphasis on reducing injury and illness in the workplace but cannot support this proposed ergonomics standard which is not based on scientific evidence and fails to determine the true financial impact of compliance.

IPC is a national trade association, representing over 2,600 member companies in the electronic interconnection industry. Founded by six companies in 1957 as the Institute for Printed Circuits, IPC grew and changed its name to reflect the broader range of electronic interconnection products.

IPC's core members are companies that produce printed wiring boards (also known as "printed circuit boards") and printed wiring assemblies. Printed wiring assemblies are printed circuit boards on which electronic components have been mounted. IPC’s membership also includes equipment and materials suppliers to the industry as well as major original equipment manufacturers that use printed wiring boards and assemblies in their products. These represent a wide diversity of products including pacemakers, airplane crash avoidance systems, missile defense controls, and cellular telephones. PWBs and PWAs are used in a variety of electronic devices that include computers, cell phones, pacemakers, and sophisticated missile defense systems. The industry is vital to the U.S. economy and employs more than 330,000 people. Industry members operate in every U.S. state and territory.

The majority of IPC member companies are small businesses that meet the Small Business Administration’s definition of "small business." Ninety percent of IPC members have sales less than $10 million; of those, 80 percent have sales less than $5 million. On average, IPC members employ approximately 100 employees and have a profit margin of less than four percent. As a result, the majority of IPC member companies would be crippled financially with implementation of yet another quagmire of regulations over the workplace that do not demonstrate any significant improvement in the health and safety of it workers. IPC has long placed a priority on reducing injuries and illness of employees in the electronics industries. It is our moral and legal responsibility and in the best interest of industry and labor. The majority of our members institute a voluntary program to protect employees against injury. These programs are designed to meet the unique safety needs of each company and better serve employees.

At this time the current base of scientific and medical knowledge does not show a direct relationship between the decline of musculosketal disorders (MSDs) and government intervention. OSHA’s own data reveals that MSDs are on the decline without the ergonomics rule. The latest figures from the Bureau of Labor Statistics show that repeated trauma injuries have declined by 24 percent since 1994. In light of this, IPC supports delaying implementation of the ergonomics standard until the National Academy of Sciences completes its review of all the scientific research related to ergonomics. Businesses, especially small businesses, should not be the testing grounds for ergonomics regulations. Small businesses can least afford to comply with regulations that are not proven to ensure worker safety.

In conclusion, IPC opposes the proposed rule and urges OSHA to reconsider moving forward with the proposed ergonomics standard which lacks scientific basis and underestimates the cost of compliance to small business. Thank you for this opportunity to provide IPC’s comments

Sincerely,

Dennis P. McGuirk
President