PMPA Testifies on OSHA's Proposed Injury and Illness Reporting Rule

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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:

No safety or health outcome benefit for workers has been established;
On line reporting will discourage recruitment of employees to manufacturing careers;
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.

Workforce Participation Rate Hits New Low- Yet We Need Skilled Workers

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This New Normal seems like a scene out of Alice in Wonderland. — This New Normal seems like a scene out of Alice in Wonderland:

The Workforce Participation Rate fell to an astonishing new low of 62.8%, and yet the Employment outlook for skilled workers in our precision machining shops is the most positive it has ever been, with 99% of respondents saying that the employment outlook will remain the same or increase over the next three months.

Alice would recognize this trend... — Alice would recognize this trend…

Americans not in the labor force exploded higher by 535,000 to a new all time high 91.8 million.

91.8 million Americans no longer in the workforce!

This is not due to just inevitable baby boomer retirements.
The estimates due to baby boomers range from 20% from the conservative Heritage Foundation to 25% from the liberal Economic Policy Institute.
And yet Manufacturing Institute estimates 82% of U.S. Manufacturers are looking for skilled workers, confirming the strength of our previously mentioned 99% positive outlook for job prospects in the precision machining industry.
Why does this matter?
” …we estimate that potential GDP is currently about 7 percent below the trajectory it appeared to be on prior to 2007.”-Reifschneider, Wascher and Wilcox IMF Paper
Graphs courtesy of Zero Hedge

4 Reasons You Can't Predict Firm Metals Pricing in 2014

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Your customers may demand that you give them firm pricing for raw materials, but here are 4 reasons that say “Ain’t gonna happen.”

" Why yes, I can hold that price firm for the year" said no one in their right mind. Ever. — ” Why yes, I can hold that price firm for the year” said no one in their right mind. Ever.

BUSINESS CYCLE Business Cycle is currently in a downward phase. what savvy organizations should be doing right now is planning for budget reductions, cross training employees, evaluate vendors for sustainability. Nothing in the business Cycle justifies firming up pricing at this time.
BIAS TOWARD GROWTH Everyone expects the prices of things to grow, particularly for commodity raw materials. The Steel Benchmarker chart for hot rolled steel band shows that this is hardly ever the case…
VOLATILITY That Steel Benchmarker chart shows a price differential ranging from 4.5% in 2012 to a high of 100% in 2008. This is why your customers want firm prices, not why you should bet your business on giving them firm prices over which you have no control.
DETERMINANTS OF DEMAND What is driving demand for the raw materials? is it even North American, or is it China or emerging economies? Global demand is typically what is driving prices here in US and around the globe. US GDP growth in 2013 was estimated to be 1.6% China’s 7.5% Pick a number. Any number.

Customer’s seek firm prices to eliminate their risk, but shoving risk onto suppliers unilaterally is not eliminating risk, it is just getting it off their desk and onto yours. Our job as sustainable, competitive, quality suppliers is to intelligently manage risk. In today’s raw material environment, saying “No!” to agreeing to hold firm prices for raw materials when you have no ability to effect that price’s firming is intelligent management of risk.
Full article on why you are not the Carnack of Metals.

4 PMPA Members to be Awarded Manufacturing Institute's STEP Award

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PMPA is proud to announce and congratulate the 4 PMPA members to be awarded the 2014 STEP Award by the Manufacturing Institute.
PMPA members named were Patricia Lewis, Berkley Screw Machine Products, Inc. Rochester Hills, Michigan; Tanya DiSalvo, Criterion Tool, Cleveland, Ohio; Kimberly Arrigoni, Haberman Machine, Oakdale, MN; and Janice Wiegand, Mercury Manufacturing Company, Wyandotte, Michigan.
The STEP Awards honor women who have demonstrated excellence and leadership in their careers and represent all levels of the manufacturing industry, from the factory-floor to the C-suite.
“These women are the faces of exciting careers in manufacturing,” said Jennifer McNelly, president, The Manufacturing Institute. “These women were selected because they each made significant achievements in
manufacturing through positive impact on their company and the industry as a whole.“
The STEP Awards are part of the larger STEP Ahead initiative launched to examine and promote the role of women in the manufacturing industry through recognition, research, and best practices for attracting, advancing, and retaining strong female talent.
A recent survey from Deloitte and The Manufacturing Institute found that nearly 82 percent of American manufacturing companies have a moderate to severe shortage of available, qualified workers. Contributing to this gap is the underrepresentation of women in the industry. While women make up approximately 50% of the labor force, that number is only about 24% in the manufacturing labor force.
On February 6, The Manufacturing Institute will recognize these 160 recipients from over 110 companies at the STEP Awards in Washington, D.C. The STEP Awards program will highlight each Honoree’s story, including their leadership and accomplishments in manufacturing. By telling the real stories of these women, we will inspire the next generation of talent to pursue careers in the industry and support current female talent within the manufacturing industry.
Official Press Release:

2013 in Review

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The WordPress.com stats helper monkeys prepared a 2013 annual report for this blog.

Here’s an excerpt:

The Louvre Museum has 8.5 million visitors per year. This blog was viewed about 180,000 times in 2013. If it were an exhibit at the Louvre Museum, it would take about 8 days for that many people to see it.

Click here to see the complete report.

December ISM Report Confirms Strength in Manufacturing

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“The PMI™ registered 57 percent, the second highest reading for the year, just 0.3 percentage point below November’s reading of 57.3 percent. The New Orders Index increased in December by 0.6 percentage point to 64.2 percent, which is its highest reading since April 2010 when it registered 65.1 percent. “– Bradley Holcomb, Institute for Supply Management.

Confirms PMPA Business Trends Experience to Date

Transportation Equipment; Primary Metals; Fabricated Metal Products; and Miscellaneous Manufacturing were among the markets reporting strengthening that are important to Precision Machining. Machinery; Electrical Equipment, Appliances & Components markets reported contraction in December.
Economic activity in the manufacturing sector expanded in December for the seventh consecutive month, and the overall economy grew for the 55th consecutive month according to ISM.

PMPA’s November 2013 Business Trends Report was similarly positive, despite seasonality at the highest value ever for a November at 116.

November is typically a slow sales month due to seasonal factors. The index is maintaining an average for calendar year 2013 of 122, and for trailing 12 months of 119. November 2013 shipments are 113% of October 2012.

The Employment Index registered 56.9 percent, an increase of 0.4 percentage point compared to November’s reading of 56.5 percent. December’s employment reading is the highest since June 2011 when the Employment Index registered 59 percent.
Why wouldn’t you be considering a career in Manufacturing?

What You Preferred in 2013

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Here are the top posts from 2013 that YOU found most interesting.
Skills DO Pay the Bills

You need skills, not just high pay, to properly hitch the cart to the horse.

We paid attention!
With over 20,000 views, we adjusted to your interest by creating a new blog focused solely on careers:
http://yourcareerfacts.com/
Second most popular was Multiple Solutions about the lesson I learned at Paul Horn Company about optimizing for product output and quality rather than lowest cost- over 14,000 views:

Accuracy and Precision in your Machining Shop

Accuracy describes 'close to true value;' Precision describes 'repeatability.' — Accuracy describes ‘close to true value;’ Precision describes ‘repeatability.’

Our post explaining accuracy and precision has had over 10,000 views.
We had two posts in our top ten addressing Safety and Lift Trucks:
OSHA Emphasis Lift Trucks
Inspection Compliance ForkLifts
And the balance at 5000 views or less each addressed Metallurgy and it’s impact on our processes and products:
Hardness vs Hardenability
5 Benefits of Cold Work
Blue Brittleness
5 Reasons to Anneal Steel
Seams on Steel Products
We started this blog to provide knowledge retention of important concepts that impact our precision machining businesses.
But you keep this blog going with your interest, forwards to colleagues, and comments on group discussion on LinkedIn where we share.
What will be 2014’s most important posts? We suspect regulatory topics to garner a lot of attention, but there is always the economy…
What would you like us to blog about in 2014?

Three Wishes For The Precision Machining Industry This Christmas

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Santa asked me to close my eyes and make three wishes for the precision machining industry. Here they are.

"Make three wishes" he said — “Close your eyes and make three wishes” he said.

Wish number 1: Have yourself a safe balance of year 2013 and 2014
We take our physical wellbeing for granted. Statistics show that we are safer at work than we are at home. But my wish is that we all pay attention to those things that could put us in harm’s way and find a way to eliminate them.
Wish Number 2: Raise your standards.
This is not original to me, even though “continuous improvement of the people and processes under your authority” has been a key tenet of my management practice (and teaching) since the early 1990’s. Alain Briot, in my mind todays preeminent fine arts landscape photographer, printed that on his business card.

Raising our standards goes beyond mere improvement of what we can control, to how we improve ourselves as well. Raise your standards.
Wish number 3: Train your people.
The time is now. Look at your bench. Who can move up? Who can’t you afford to take out of production to train on setup? What will you do when you lose them because you didn’t give them the opportunity to grow and train and become even more valuable.? Training is our number one job in the industry today. Our employees add value through the application of their skills and knowledge and talent to our processes. Train them!
When I opened my eyes, Santa was gone. He left a note: it said: Everything that you wished for is up to you. I know you will make sure to get this done. I gotta run and help the folks who the government regulators are trying to close down. Merry Christmas!
Or something like that.

I opened my eyes and I was holding this note... — I opened my eyes and I was holding this note…

Precision Machining Industry Shipments Surprisingly Strong in November

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PMPA’s Business Trends Index for November 2013 is 116, down 10 points from last month’s value, yet at the highest value we recall for November. November is typically a slow sales month due to seasonal factors. The index is maintaining an average for calendar year 2013 of 122, and for trailing 12 months of 119. November 2013 shipments are 113% of October 2012.

We are pleased to see that sales in November were above those in November 2012. While the last calendar quarter is historically weak for our shops, we have a nice tailwind of sales for the year to date at 122 average for the calendar year. With sales this strong in 4^th quarter, we think that savvy shops will be lining up sourcing for the even stronger sales likely once we turn the calendar page to 2014. Have you been sharing expectations with your key suppliers?
Biggest surprise- 99% of responding companies expect employment in their shops to remain the same or increase!
Get our November PMPA Business Trends Report Here.

Improve Tracking of Workplace Injuries and Illnesses-Proposed Rule Beware

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No mention at all of "we're going to post your data on line for the world to see." — No mention at all of “we’re going to post your data on line for the world to see.”

” The proposal does not add any new requirement to keep records; it only modifies an employer’s obligation to transmit these records to OSHA.”- OSHA Director David Michaels
Warning to employers, when Government Officials only give you half the story, you are not getting the full truth.
What is the rest of the story?
Take a look at item II.2. e in the Federal register notice of the NPRM:

Why does the federal government insist that private industry guard privacy rights, when it is the biggest offender regarding the publication of private data?
As employers, we agree that injuries and illnesses should be tracked and reported to officials for official purposes.
We disagree that the data reported for statistical and enforcement purposes should be broadly disseminated and made accessible for those with no regulatory need.
The president famously said that “If You Can’t Trust Government, We’re Going to Have Some Problems”

Telling employers that “The proposal does not add any new requirement to keep records, it only modifies an employer’s obligation to transmit these records to OSHA” is disingenuous at best.
OSHA will hold an informal public meeting on the Improved Tracking of Workplace Injuries and Illnesses proposed rule on January 9th, 2014 in Washington DC.
A Federal Register notice announcing the public meeting will be published shortly. We need to tell them that we object to this proposal.
An agency that says the only thing that changed is how we transmit the records to OSHA while it intends to publish them online is not telling the whole truth.
We agree with the President. “If we cannot trust the executive branch with our data, we’re going to have some problems.”
Federal Register
Can’t Trust the Government