IV. Regulatory Impact, Regulatory Flexibility and Environmental Assessment of Revisions to Subpart I, Personal Protective Equipment

Introduction

In 1971, OSHA adopted its current standards for personal protective equipment (PPE) from national consensus standards under section 6(a) of the OSH Act. Since then, advances in PPE technology have resulted in greater occupational protection in workplaces where equipment innovations have been adopted. In this final rule, OSHA promulgates a nationwide standard for PPE that reflects these improved means of hazard prevention.

Executive Order 12866 (58 FR 51735) requires that a Regulatory Impact Analysis be prepared for any "significant regulatory action". A "significant" rule would have an annual effect on the economy of $100 million or more or adversely affect in a material way the economy, a sector of the economy, productivity, competition, jobs, the environment, public health or safety, or state, local or tribal governments or communities. In addition, the Regulatory Flexibility Act (5 U.S.C. 601, et seq.) requires an analysis of whether a regulation will have a significant economic impact on a substantial number of small entities. Finally, section 6(f) of the Occupational Safety and Health Act provides that, where a party has challenged the validity of an OSHA standard in the Court of Appeals, the determinations of OSHA (such as findings regarding the nature and severity of workplace hazards and the feasibility of identified abatement measures) shall be conclusive if supported by substantial evidence in the record considered as a whole.

OSHA determined, based on the Agency's Preliminary Regulatory Impact Analysis [1] and its review of the rulemaking record, that the final rule for General Industry PPE is not a "significant regulatory action" for the purposes of review under Executive Order 12866. However, in order to satisfy the various statutory requirements placed upon the Agency and to further explain why OSHA has classified this regulatory action as "non-significant" for Executive Order 12866 purposes, OSHA presents this Final Regulatory Impact, Regulatory Flexibility and Environmental Impact Assessment.

Industry Profile

Based on a report prepared by Eastern Research Group under contract to the Department of Labor [2], OSHA has determined that the hazards addressed by the personal protective equipment standard are present in varying degrees in virtually all workplaces covered by the OSHA General Industry standards (29 CFR 1910). The extent of the rule's impact will vary by industry depending on the hazards, the types of occupational activity and current practices regarding PPE use.

Many types of PPE have been in widespread use in industry for many years. However, until recently very little statistical data existed to determine the number of employees who either are using PPE or who should be wearing PPE by virtue of the hazards to which they are exposed.

OSHA's inspection data document that approximately 3.5 percent of all planned safety inspections result in citations under the existing PPE standards. The inspection data identifies the standard industrial classification (SIC) of the establishment, size of plant workforce, union status, and information related to the inspection itself; less frequently reported are data on degree of hazard present in workplaces, the number of workers exposed to the hazard, or the type of PPE required.

In its Preliminary Regulatory Impact Analysis [1], OSHA examined injury statistics for affected industry sectors. Among the accident databases searched by OSHA were Work Injury Reports (WIR) published by the Bureau of Labor Statistics (BLS). These reports examine cases where a worker was injured and provide evidence that many workers are not wearing adequate personal protective equipment. Based on the BLS data, relatively few firms with serious recordable injury cases have performed a formal assessment of the potential hazards in their workplace. In addition, little training was offered to workers regarding the importance of using protective equipment in these firms.

To obtain accurate information on the need for personal protective equipment and the extent to which that need is being met, OSHA conducted a national survey in 1989 [3,4,5]. The survey sampled 5,361 establishments, representing 1.1 million establishments in 61 SIC groups. The survey identified the hazards related to industrial processes and the types of PPE required when working in or near these processes. The survey solicited information on PPE practices and safety procedures and assessed whether engineering controls such as protective guards or overhead nets were in place. Answers to survey questions were used to evaluate the appropriateness of PPE use. Survey questions also addressed PPE training and hazard assessment. (See the background document and appendices in this docket for more detailed information on the survey and supporting data related to this analysis.)

Table 1 shows the major industry groups covered by the PPE standard, the total number of affected establishments, total affected employment, number of production employees and number of employees exposed to PPE-related hazards. Of the 16.9 million production workers, the survey identified 11.7 million exposed workers within 1.1 million establishments who should be wearing some form of PPE. These numbers are lower than was indicated in the PRIA, due to a refinement in the analysis regarding affected population. Occupational categories identified by OSHA as having a significant degree of required PPE use include craft, operating, maintenance and material handling employees. These categories encompass most production employees and are most likely to be affected by this standard. However, as noted in the PRIA [1, p. II-2-4], OSHA has previously estimated over a million other workers may also be exposed to hazards requiring PPE use in the rest of general industry(1).

__________
  Footnote(1) As was indicated in the PRIA, while all general industry
workers are potentially affected by these standards, exposed workers are
heavily concentrated in certain occupations and in certain industries.
Building upon information provided for the PRIA and comments to the
record, this final analysis focuses on those groups of workers and
industries judged to have a heavy concentration of PPE use. In this
analysis population at risk was determined by survey results indicating a
hazard that required the use of PPE. The PRIA had used the term
"population at risk" to refer to all workers in two "production worker"
job categories in general industry [1, p. II-1-5]. It should be noted that
this analysis in no way implies that other workers may not be exposed to
hazards preventable by PPE, but simply that the great majority are found
in certain specific job categories and industries.

    TABLE 1 - Number of Establishments and Employees in Industries
              Affected by the Personal Protective Equipment Standard
___________________________________________________________________________
                             Total        Total     Production   Employees
 SICs    Industries        Establish-   Employees    Employees    At Risk
                             ments
___________________________________________________________________________
20,21  Food & Tobacco......  23,388     1,673,287    1,196,818      782,205
22     Textiles............   6,439       727,651      596,846      255,815
23,31  Apparel & Leather...  25,708     1,239,402      964,677      558,884
24     Lumber & Wood
         Products..........  37,063       739,296      597,764      405,054
25     Furniture &          Fixtures..........  10,563       515,866      412,323      306,280
26     Paper & Allied
         Products..........   6,732       680,961      479,730      387,578
27     Printing &          Publishing........  60,836     1,499,451      680,370      462,259
28     Chemicals...........  12,411     1,023,169      497,054      402,925
29     Petroleum Refining..   2,158       166,032       44,169       33,805
30     Rubber & Plastics...  14,703       851,467      565,705      393,468
32     Stone, Glass,
         Concrete..........  15,351       550,779      400,987      282,065
33     Primary Metals......   7,130       741,297      549,603      476,145
34     Fabricated Metals...  34,605     1,401,605      921,660      638,577
35     Machinery &          Computers.........  53,031     2,032,338     1,018,420     788,598
36     Electric &          Electronics.......  17,836     2,063,033     1,204,266     810,492
37     Transportation
         Equipment.........   9,688      1,762,926    1,113,656     894,417
38,39  Misc. Manufacturing.  24,860      1,091,140      599,624     410,532
41,42  Transportation...... 124,121      1,770,983    1,258,897     688,183
48     Communications......  23,505      1,281,837      788,800     642,609
49     Utilities...........  17,741        934,650      334,492     266,440
501,
 55,75 Automotive Trade &          Services.......... 326,793      3,066,501    1,373,718     803,309
50,51,
  52   Wholesale & Retail
         Trade............. 189,947      2,056,173      963,641     822,312
7692   Welding Repair......   6,653         31,800       24,622      20,317
13     Oil & Gas
         Extraction........  26,957        396,519      117,579      92,602
078,08 Horticulture &          Forestry..........  46,294        290,552      173,863     106,782
___________________________________________________________________________
  TOTAL                   1,124,513     28,588,715   16,879,284  11,731,653
___________________________________________________________________________
  Source: U.S. D.O.L., OSHA, Office of Regulatory Analysis, based on the
results of a 1989 nationwide survey.

From survey results OSHA developed a profile of the affected population by exposed bodily area (anatomical part), summarized in Table 2. As the table shows, almost 8.8 million workers are exposed to foot injury, while the potential for hand injury exists for 4.7 million workers. Other anatomical parts covered by this rule are eyes (2.8 million workers at risk), head (1.9 million workers) and face (381,000 workers).

     TABLE 2 - Number of Employees and Parts of the Body Requiring
               Personal Protective Equipment Among the Population at Risk

(For Table 2, Click Here)

Technological Feasibility and Costs of Compliance

Technological Feasibility

The existing and revised standards for subpart I require personal protective equipment wherever necessary by reason of the hazards of processes, environment or worker activity. New 1910.132(d) requires workplace hazard assessment and new 1910.132(f) requires employee training in the use of PPE. The revised standards for eye and face protection, protective headwear and foot protection update, prospectively, references to pertinent consensus standards. OSHA expects that employers will be able to comply with the new and revised requirements without difficulty, because the means of compliance are readily available and because the final rule "grandfathers" equipment that complies with the existing standards.

OSHA anticipates that the new requirements for hazard assessment, prohibition of defective and damaged equipment, and employee training can be implemented with available technical personnel and other resources. OSHA's survey probed the extent to which firms have already adopted the elements of a PPE program. Comments in the record were also evaluated in order to establish current industry practices.

On the basis of evidence in the record, including results from the OSHA PPE survey, OSHA has determined that the final PPE standard is both technologically and economically feasible.

Costs of Compliance

OSHA estimated compliance costs using data on current practices and exposed population from the PPE survey. Aggregating costs across industry sectors, OSHA estimates a total annual compliance cost of new provisions in the revised rule will result in a cost of $52.4 million. Total compliance costs by industry sector are presented in Table 3.

    TABLE 3 - Industry Compliance Costs for the Personal Protective
                     Equipment Standard
__________________________________________________________________________
                                                                Total
                             Annualized                      Annualized
                              Cost of       Annualized         Cost of
                             Compliance      Cost of         Compliance
  SICs       Industries         with         Hazard             with
                              Training      Assessment       Revisions
                             Requirement                       to PPE
                                                              Standard
__________________________________________________________________________
20,21    Food & Tobacco ...  $2,672,097      $563,775        $3,235,871
22       Textiles .........  $1,533,441      $170,892        $1,704,333
23,31    Apparel & Leather.  $2,582,549      $742,021        $3,324,570
24       Lumber & Wood
           Products .......  $1,676,192      $584,579        $2,260,771
25       Furniture &            Fixtures .......  $1,250,063      $263,721        $1,513,783
26       Paper & Allied
           Products .......  $1,403,654      $149,625        $1,553,279
27       Printing &            Publishing .....  $3,346,716    $1,083,078        $4,429,794
28       Chemicals ........  $1,059,463      $116,425        $1,175,888
29       Petroleum Refining     $44,768       $22,235           $67,003
30       Rubber & Plastics.  $1,312,997      $339,299        $1,652,296
32       Stone, Glass,
           Concrete .......    $591,905      $237,192          $829,097
33       Primary Metals ...    $688,419      $142,911          $831,330
34       Fabricated Metals.  $1,073,787      $610,317        $1,684,104
35       Machinery &            Computers ......  $1,694,596      $914,849        $2,609,445
36       Electric &            Electronics ....  $3,259,889      $349,067        $3,608,956
37       Transportation
           Equipment ......  $1,748,188      $152,397        $1,900,586
38,39    Misc.
           Manufacturing .. $1,525,950       $297,213        $1,823,163
41,42    Transportation ... $1,345,878     $1,873,465        $3,219,343
48       Communications ...   $302,276       $105,567          $407,843
49       Utilities ........   $466,182       $118,261          $584,444
501,55,
75       Automotive Trade
           & Services ..... $3,873,396     $4,772,142        $8,645,538
50,51,
52       Wholesale &            Retail Trade ... $1,757,275     $1,736,471        $3,493,746
7692     Welding Repair ...    $44,047        $50,749           $94,796
13       Oil & Gas
           Extraction .....   $927,521       $175,555        $1,103,077
078,08   Horticulture &            Forestry .......   $282,269       $373,659          $655,928
___________________________________________________________________________
TOTAL                      $36,463,518    $15,945,464       $52,408,983
___________________________________________________________________________
  Source: U.S. Department of Labor, OSHA, Office of Regulatory Analysis

OSHA's survey identified 433,149 establishments which need to take steps to come into compliance with the new provisions for hazard assessment. (Of 825,265 affected establishments, approximately 47 percent already had a hazard assessment program in place.) The cost to conduct hazard assessments was estimated to be $15.9 million per year, assuming a reassessment is conducted once every five years.

The new provision for PPE training would affect approximately 10.8 million employees estimated in need of PPE training, at an annual cost of $36.5 million.

Estimates for the cost of providing PPE training differ from those in Preliminary Regulatory Impact Analysis due to comments received and results from OSHA's PPE survey. This information indicated that the problem of PPE non-usage is considerably more widespread than originally estimated. Correspondingly, this indicated that the population requiring PPE training was larger than originally estimated.

Assessment of Hazards and Benefits

Injuries

OSHA believes that the risk of fatality and injury to workers is unacceptably high among sectors affected by the revised personal protective equipment standard. The revised PPE standard is designed to enhance compliance with existing requirements and ensure future compliance related to a heightened level of hazard awareness and training. These changes to the standard should help to eliminate or reduce accidents within industries subject to the rule.

The standard has performance-oriented provisions addressing eye, face, hand, head and foot hazards that allow employers to adopt the most up-to-date PPE for use in their establishment. The flexibility to substitute new materials and technologies should produce more comfortable and protective PPE. An increase in worker acceptance and use of PPE should translate into additional benefits. OSHA's expectation is that increased use of better equipment will prevent or lessen the severity of many incidents.

According to BLS statistics in Occupational Injuries and Illnesses in the United States by Industry, 1989 [6], there were a total of 1.6 million lost-workday cases and 1.8 million non-lost-workday cases during the survey year. Eastern Research Group [7] analyzed survey-related data, which were used to extract the number of these injuries that were related to use (or nonuse) of PPE. In turn, BLS Work Injury Reports were analyzed to estimate what portion of those injuries related to inconsistent or inappropriate use of PPE, or lack of hazard identification. Injuries prevented in significantly affected industry sectors are shown in Table 4. Since injuries will be prevented in some other industry sectors as well, total estimates are conservative.

TABLE 4 - Injuries Prevented Through Compliance With New PPE Requirements
__________________________________________________________________________
                                    Lost          Lost         Non-lost-
 SIC         Industry              Workday       Workdays       workday
                                    Cases       Prevented        Cases
                                  Prevented                    Prevented
__________________________________________________________________________
20,21  Food & Tobacco ..........    3,178         57,195          3,945
22     Textiles ................      710         12,780          1,405
23,31  Apparel & Leather .......      607         11,531          1,482
24     Lumber & Wood Products...    1,850         35,151          2,375
25     Furniture & Fixtures ....    1,216         20,680          1,818
26     Paper & Allied Products .      978         21,512          1,718
27     Printing & Publishing ...      755         14,340          1,361
28     Chemicals ...............      783         14,870          1,082
29     Petroleum Refining ......      120          2,529            125
30     Rubber & Plastics .......    1,873         31,837          2,625
32     Stone, Glass, Concrete ..      989         19,782          1,578
33     Primary Metals ..........    1,829         36,587          2,821
34     Fabricated Metals .......    3,506         63,114          6,097
35     Machinery & Computers ...    3,372         57,324          6,744
36     Electric & Electronics ..    1,343         24,173          2,578
37     Transportation Equipment.    1,966         37,359          5,829
38,39  Misc. Manufacturing .....    1,044         19,374          1,610
41,42  Transportation ..........    2,127         54,710          2,355
48     Communications ..........      255          4,846            357
49     Utilities ...............      740         13,318            867
501,
55,75  Automotive Trade &          Services...............    1,423         26,005          7,942
50,51,
52     Wholesale & Retail Trade.    6,243        109,743          7,005
7692   Welding Repair ..........       90          1,424             91
13     Oil & Gas Extraction ....      389         11,680            404
078,08 Horticulture & Forestry .      537         10,358            316
__________________________________________________________________________
                                   37,924        712,223         64,530
___________________________________________________________________________
  Source: U.S. Department of Labor, Bureau of Labor Statistics and OSHA,
Office of Regulatory Analysis.

OSHA estimates that 712,000 lost workdays(2) and 65,000 non-lost workday cases will be realized from compliance with requirements for employee training and workplace hazard assessment. These benefits will be gained through selection of more appropriate PPE, increased awareness of hazards and improved consistency in use. These benefit estimates exceed those of the PRIA because OSHA has determined that current compliance with the PPE standards is poorer than was estimated in the PRIA. In addition, OSHA believes these requirements will enhance compliance with existing requirements, thereby preventing more injuries; however, the extent of these benefits are difficult to quantify.

__________
  Footnote(2) Recent research by Arthur Oleinick identifies a possible
underestimation of lost workdays when reference periods are bounded by
calendar years, as in the BLS survey. For elaboration of this point, see
Oleinick [8].

OSHA also estimated the number of fatalities associated with the absence of personal protective equipment. From an analysis of BLS, NIOSH and OSHA accident data, OSHA estimates that 125 fatal head injuries occur annually. While most fatal head injuries are the result of crushing injuries, falls, explosions and other traumatic events beyond the scope of this standard, some are preventable with the use of head protection. Based on a review of OSHA accident abstracts and an understanding of the rule's scope and effectiveness, OSHA estimates that 4 head injury fatality cases are preventable each year through compliance with the new provisions of the standard.

Cost Savings

Based upon these estimated reduction in injuries, OSHA estimates that society will reap substantial economic benefits from prevented injuries. Lost work time injuries can be particularly expensive.

PPE is uniquely effective in preventing eye injuries, for example, which can be severely debilitating. Dr. Leonard Parver [9, pp. 28-29] of Georgetown University's ophthalmology department elaborated on this cost to employers:

These injuries tend to be very devastating. They have severe impact on the patient in terms of vision, and the costs are phenomenal. We estimate the costs of hospitalizing these patients at $250 million per year. That's just for the hospital stay; that doesn't include lost work days and compensation costs. This is a very significant problem, and very, very preventable. We're not talking about reinventing the wheel here. We have the means of doing this. We have adequate eye protective gear. It's a matter of educating the workforce that this is necessary.

While employers typically bear only a fraction of the costs related to injuries, these costs can be substantial. Employers specifically will benefit from reduced lost production time, administrative time spent preparing insurance claims and accident reports and replacing injured workers. Based on a 1981 study by Levitt and coworkers [10], OSHA estimates the cost to employers from the average lost worktime injury is at least $4000(3). This cost includes:

__________
  Footnote(3) Levitt's wage rates were adjusted to reflect current wage
conditions in general industry [11]. In light of the National Safety
Council estimates presented later in this document, given the debilitating
severity of many PPE accidents (eye, head), and the surge in workers
compensation costs in recent years, an estimate of $4000 per injury is
likely to be conservative.


  *  Administrative cost of handling insurance company claims.
  *  Wages paid to other workers for the time not worked (work
interrupted).
  *  Cost of scheduling and funding overtime necessitated by the accident.
  *  Cost to find and train a replacement worker.
  *  Extra wage cost to rehabilitate the returning worker at a reduced
capacity.
  *  Cost to clean up, repair, or replace damage from the accident.
  *  Cost of wages for supervision associated with the accident.
  *  Cost for safety and clerical personnel to record and investigate the
accident.

Other nonquantifiable costs associated with accidents, such as increased anxiety among non-injured workers, the loss of employee goodwill towards the employer, and the impact on public perception of a company and its products were not considered in the Levitt study.

Based on the Levitt study and the estimated 37,924 lost workdays prevented, OSHA estimates that the rule will save firms over $150 million annually.

However, as noted above, the cost of workplace injuries is typically borne primarily by employees themselves. The National Safety Council recently calculated the societal cost per lost worktime injury at $27,000 [7,p. 35], by factoring in long-term wage losses, medical expenses, administrative expenses and miscellaneous employer costs. Applying this figure to OSHA's estimate of 37,924 lost workday injuries prevented annually, revisions to this rule should save society (employees, employers and third parties) over $1 billion annually.

These estimates of the economic benefits of the rule may be conservative, since the benefits analysis focuses on injuries prevented, not reduced severity of injuries. To the extent the rule results in nonlost workday injuries, as opposed to disabling lost workday injuries, the economic benefits may be greater yet. In sum, OSHA estimates the rule will save society over $1 billion annually, dwarfing the initial $52 million investment. Employers themselves should save over $150 million through full compliance with revisions to the PPE standard, approximately three times the estimated cost of compliance.

Economic Impact and Regulatory Flexibility Analysis

OSHA analyzed the potential economic impact of the revised PPE standard and has determined that none of the major industry groups subject to the standard would experience a significant economic burden as a result of compliance, even before cost savings to employers are factored in. Table 5 presents average compliance cost, revenue, profit, and economic impacts of the standard for establishments in affected industry groups. If all of the compliance costs are passed through to the consumer, OSHA estimates that the average price increase would be negligible, less than 0.001 percent, calculated as the ratio of total compliance cost to industry sales. The maximum price increase in any industry would be less than 0.005 percent. Given the minuscule price increases necessary to cover these safety investments, employers should be able to pass along compliance costs to their customers. However, even if all costs were absorbed by the affected firms, the average reduction in profits would be approximately 0.01 percent, the largest being 0.06 percent. OSHA, therefore, does not expect the revised standard to have a significant economic impact on affected firms or industries(4).

__________
  Footnote(4) In the Preliminary Regulatory Impact Analysis [1], OSHA
analyzed the entire spectrum of affected industries, and had determined no
significant economic impact would result on establishments on any
industry, with substantially less impact in those establishments without
heavy PPE use. This determination was reached even though the PRIA
included costs not directly attributable to the proposal, resulting in a
total cost estimate which was nearly twice the cost estimated in this
final analysis. Accordingly, OSHA reaffirms that establishments in those
industries will incur minimal economic impact.


          TABLE 5 - Economic Impact of the PPE Standard on
                    Affected Establishments (Gross Costs)

(For Table 5, Click Here)

In accordance with the Regulatory Flexibility Act of USC 601 et seq.), OSHA also analyzed the economic impact on small establishments (19 or fewer employees), looking particularly for signs that the rule would pose excessive burdens per employee, relative to impacts faced by larger entities. OSHA has determined that, in relation to compliance with the standard, equipment purchases and labor utilization will to a great extent depend positively on size of workforce; smaller firms are not expected to incur relatively higher costs per worker. As shown in Table 6, OSHA estimates that the average price impact for small establishments will be 0.002 percent, while profit impacts will not exceed 0.04 percent under the assumption that all compliance costs are absorbed by firms. These impacts are judged to be relatively minor; therefore, the PPE standard is economically feasible for small establishments.

   TABLE 6 - Economic Impact of the PPE Standard on Affected Small
             Establishments (19 or Fewer Employees) (Gross Costs)

(For Table 6, Click Here)

Environmental Impact

The revisions to the PPE standard have been reviewed in accordance with the requirements of the National Environmental Policy Act of 1969 (42 U.S.C. 4321, et seq.), the regulations of the Council on Environmental Quality (40 CFR part 1500 through 1517), and the Department of Labor's NEPA procedures (29 CFR part 11). As a result of this review, OSHA has determined that the new PPE standard will have no significant environmental impact.

References

1. Preliminary Regulatory Impact and Regulatory Flexibility Analysis of the Personal Protective Equipment Standard, U.S. Department of Labor, Occupational Safety and Health Administration, Office of Regulatory Analysis, June 30, 1989. Exhibit 4-6.

2. Eastern Research Group. Economic Analysis of the Revised General Industry Personal Protection Equipment Standard (CFR Part 1910.132 - 1910.140). Prepared for the U.S. Department of Labor, Occupational Safety and Health Administration under Contract No. J-9-F-0057. Arlington, MA. October 1988, as described in Exhibit 4-6.

3. PPE Survey Description. Exhibit 4-1. 4. Survey Instrument. Exhibit 4-2. 5. Tables of Weighted Survey Data. Exhibit 4-5. 6. Bureau of Labor Statistics. Summary and Analysis of Injuries and Illnesses in the United States by Industry, 1989. U.S. Department of Labor, Bulletin 2379, April 1991.

7. Eastern Research Group. Summary and Analysis of Injuries and Illnesses in a Data Base of OSHA Draft Form 200s (1986-1987). March 1990. Exhibit 32.

8. Oleinick, Arthur, et al. "Current Methods of Estimating Severity for Occupational Injuries and Illnesses: Data From the 1986 Michigan Comprehensive and Compensable Injury and Illness Database." American Journal of Industrial Medicine 23 (1993): 231-252.

9. "In the Blink of an Eye", Occupational Hazards, June 1991. 10. Levitt, Raymond, et al. Improving Construction Safety Performance:

The User's Role. Stanford University Department of Civil Engineering. Technical Report No. 260. August 1981. Exhibit 3-20, Docket S-012A.

11. Eastern Research Group, Inc. Industry Profile Study of a Standard for Control of Hazardous Energy Sources Including Lockout/Tagout Procedures. Prepared for the U.S. Department of Labor, Occupational Safety and Health Administration, under Contract J-9-F-2-0047, Exhibit 3-15, Docket S-012A.

12. National Safety Council, Accident Facts, 1993 Edition.

[59 FR 16334, April 6, 1994]