Comments Submitted by: James Thornton for Northrop Grumman Newport News

November 13, 2007 Docket Office Docket No. OSHA?2007?0034 U. S. Department of Labor, OSHA 200 Constitution Avenue, NW, Room N-2625 Washington, D.C. 20210 Dear Docket Officer: Northrop Grumman Newport News appreciates the opportunity to respond to OSHA?s request for comments regarding the proposed ergonomics guidelines for shipyards. Northrop Grumman Newport News employs approximately 21,000 employees at multiple sites across the nation, including VPP member shipyards in Virginia and California. The Virginia site is the nation's largest shipyard and largest private employer in the Commonwealth. Established in 1886, the shipyard occupies approximately 500 acres and 2-1/2 miles of waterfront on the James River in Newport News, Virginia. Northrop Grumman Newport News supports OSHA?s initiative to provide guidelines to protect workers from ergonomic hazards. Control of ergonomic injuries is especially challenging in shipyard environments where working conditions are constantly changing and employees must often work in situations that are not conducive to good ergonomic practices. Ergonomic injuries represent a significant portion of the total injuries that occur in shipyards; they have a correspondingly high cost for the employers, employees and their family units. Overall, we concur and support the guidelines as written. We offer the following comments as recommendations that we believe will enhance the document and provide an improved tool to help employers reduce ergonomic illness and injury: 1. The values presented in the Introduction in the table of MSD incidence rates resulting in days away from work do not appear to make sense in light of the total recordable injury and illness rates published by the BLS for shipbuilding and repair and our experience. The 2005 shipbuilding rate published by the BLS for cases resulting in days away from work is 6.3 cases per 100 employees. It is our experience that MSDs constitute almost half of these cases, so we would expect to see a rate of almost three times the 0.974 cases per 100 employees presented in the table. 2. In the section Involving Employees we recommend that OSHA provide additional emphasis on the importance of maintaining a feedback system to employees. If management does not follow through with employees? recommendations for improvements or communicate the reasons that particular suggestions were not acted upon, it is our experience that after a time employees will stop making those suggestions. 3. In the section A Process for Protecting Employees we recommend substituting the word ?requirements? for the word ?condition? in the last sentence of the first paragraph. We feel that changing the sentence to read, "?this process should be tailored to an individual shipyard's requirements? more clearly communicates the importance that employers understand the unique physical, cultural and business drivers of their respective shipyards. 4. In the section Evaluating Progress we recommend OSHA emphasize measuring the reduction of identified risk in addition to trailing (outcome) indicators. While outcome-based measures such as cost and injuries are important, eliminating or reducing hazards and associated risks is more proactive and controllable. Management can affect the work place incidence rate and production by reducing the MSD risk and documenting those reductions. The employees can see positive input from management and will experience an improved working condition. 5. We recommend that in the section Implementing Solutions there be recognition of the importance of documenting, proceduralizing and institutionalizing ergonomic solutions. In shipyards, job cycle times can vary from days to years. To sustain ergonomic improvements in a shipyard, there must be a system of capturing work improvements and making sure those improvements are incorporated in the work practices of future jobs and tasks. Some formal method of standardized work practices and risk assessment must be a part of the work culture. 6. In the example titled Blasters and Sprayers the guideline describes a process for attaching a blasting rig to a personnel platform to permit remote blasting. While we agree that this reduces the risk of injury to the blaster, we believe that this operation requires further evaluation. For instance, we are uncertain about the remote operation of deadman controls or whether this arrangement meets manufacturer?s requirements. We recommend OSHA add additional cautionary statements if this example remains in the guidelines. In summary, we feel that the guidelines do a good job of providing specific solutions to certain identified problems. However, the dynamic nature of shipbuilding makes it almost impossible to identify and prioritize all of the types of work that can result in ergonomic injury or illness, and therefore, we believe these guidelines will have limited impact on the overall reduction of ergonomic risks and injuries. We recommend that the guidelines be expanded to include more risk assessment tools to help employers identify and evaluate ergonomic hazards that are encountered in shipbuilding and repair. Perhaps the Agency might consider some type of formalized meeting (or hearing) to discuss these guidelines and the concept of ergonomics in shipyards. We feel that a full dialogue on this topic including all stakeholders would benefit all. Again, we appreciate the opportunity to provide comments on this draft document and hope that OSHA finds these recommendations useful. For further information, please contact me at (757) 380-4651. Sincerely, James R. Thornton Director, Environmental, Health & Safety James Thornton, Northrop Grumman Newport News