Comment from James Hardin, Grady-White Boats, Inc.

These comments are being offered by Grady-White Boats, Inc. Grady-White Boats manufactures glass-reinforced coastal recreational sportfishing boats that range from 18’ to 36’ in length. Grady-White is located in Greenville, NC and employs about 170 people. Grady-White is a privately held small business that has continuously manufactured boats for over 50 years. Grady-White manufactures boats in a factory that land-locked and is not a ship yard; we are not located on any navigable waterways. Our manufacturing operation is no different than a company that is manufacturing other fiberglass reinforced products such as bath tubs or swimming pools. The risks and exposures to our employees is no different than any manufacturing facility producing fiberglass reinforced products using the traditional open-molding process. Grady-White builds boats for recreational use. The product is designed and built to meet USCG regulations for recreational use. As a manufacturer we have no method to track how the product is used in the field and believe the definition of a recreational vessel should not be changed as proposed. Occasionally, one of our dealers may sell a boat to a government agency such a state’s Department of Natural Resources. This sell occurs without any communication to us, as the manufacture, regarding the ultimate retail boat buyer. We do not, as a manufacturer, bid on any state or federal purchases. All bids of this nature are performed by the dealer. Our dealers are independently owned businesses that are not under our control or influence regarding their customers. It is also burdensome and unreasonable to expect a manufacturer to investigate the way(s) a boat is being used that is designed and sold as a recreational vessel. Grady-White would request that the department should only remove the length limit for boat repair in the existing definition. There should be a clear threshold defined that would allow a facility such as ours to remain a state worker’s compensation facility and not have to manage a workforce that is segregated as covered under worker’s comp and LHWCA. We also feel that having to offer dual coverage under NC State’s worker’s comp and LHWCA would be redundant and wastefully expensive for little benefit to our workforce. The current Worker’s Comp system is more streamlined and more efficient than the LHWCA from our understanding. This efficient process benefits the work force as well as the employer. Grady-White has never had coverage under LHWCA. Currently we do not have LHWCA coverage and we are satisfied with the Worker’s Comp Insurance currently in force. Our WC insurance is sufficient for our needs and has historically provided all assistance needed to injured team members here at Grady-White Boats. The WC insurance provided by North Carolina is cost effective and reflects directly on our excellent incident experience. We are able to directly affect our WC insurance cost by managing our facility as a safe and injury free place to work. Controlling Worker’s Comp costs is under our direct control and provides a great incentive to maintain a safe and healthy manufacturing facility. We have not researched the cost of LHWCA versus Worker’s Comp due to limited resources we have available during this unprecedented down market we have been experiencing for the last couple of years. It would be assumed the LHWCA coverage would more expensive than WC due to the extreme differences between building or repairing a ship versus a small recreational vessel. This unneeded and unjustifiable change does nothing to increase benefits to our employees it appears to simply create added expense. We would also request that the new walk in/walk out clarification be removed and create a “bright line” test to determine if a facility’s employees are covered under Worker’s Comp or LHWCA. Thank you, Jim Hardin