Wheel weights and/or fluid in tires: Prevent spinning and rapid tire wear and increase traction Prevent front wheel side slippage and provide improved control D Beginning in 1972, tractors and trailed equipment on highways must have SMV emblems. Although not required, flasher lights and turn signals are excellent safety devices When leaving a field to enter a main road, check both ways to be sure that the road is clear When making a left turn off a highway be sure to look in both directions for approaching automobiles. Wherever a wide shoulder permits, operate the tractor off the highway on the shoulder APPENDIX D Hon. WIILIAM L. HUNGATE, NATIONAL ASSOCIATION OF MANUFACTURERS, July 18, 1972. Chairman, Subcommittee on Environmental Problems Affecting Small Business, House Select Committee on Small Business, Washington, D.C. DEAR MR. CHAIRMAN: We appreciate the opportunity of presenting our views with respect to the impact of the Occupational Safety and Health Act on business and industry in general and on the smaller businessman in particular. NAM membership includes manufacturers of all sizes. In terms of people employed, NAM member companies provide gainful employment for 15 million of the 19 million persons engaged in manufacturing industries. Significantly, more than 50 percent of our members employ fewer than 100 people, and of this group 20 percent employ fewer than 25 people. Another 34 percent of our total membership employ fewer than 500. Thus, over 80 percent of our membership can be considered as composed of "small company" employers. These figures are cited to emphasize the fact that NAM represents a broad cross-section of the manufacturing community. When President Nixon signed the Williams-Steiger Occupational Safety and Health Act into law, he said it was one of the most important pieces of legislation ever passed by the Congress of the United States. This was a most prophetic statement, particularly in view of the reaction to its impact during the first year of implementation as demonstrated by testimony before this Subcommittee. It is indeed a most pervasive and comprehensive law and it impinges upon almost every aspect of the day-by-day operations of all business to a greater extent than probably any other current law. The experience reported by our members during this first year of the Occupational Safety and Health Act corroborates the fact that it has had a tremendous impact on their operations and has been burdensome in many respects. While this was anticipated and is true of all companies, it is particularly true of the smaller business organizations. They are more susceptible to the burden of complying with the massive regulations promulgated and the expense involved in bringing work-sites into compliance. The small employer in many instances lacks the staff capability for analyzing, interpreting and implementing the thousands of standards promulgated since the effective date of the Act. NAM believes that some way must be found to assure the continued protection of employees but at the same time insure that the burden imposed by the Federal Government does not place the employer's business or the employee's job in jeopardy. One of the obvious aids which could be employed is that of amending the Occupational Safety and Health Act to provide technical assistance and consultative services to an employer at the work-site without the peril of a mandatory citation and penalty for a discovered hazard. In addition, some way should be found to enable an employer to remedy violations without imposing a financial obligation which would jeopardize his ability to continue in business and to provide sustained employment. Further, we believe that some way must be found to acquaint employers, particularly the smaller ones, with the obligations and responsibilities imposed by the Act. There should also be a simplified appeal procedure which is capable of being understood and pursued by a layman rather than requiring the expense of employing an attorney. In addition, the law should provide for some flexibility for first offenses with respect to the mandatory issuance of citations and penalties. It is our belief that in such cases a citation without penalty would be adequate incentive for an employer to remedy the alleged violation. Another suggestion we offer is one that was embodied in our testimony before both the House and Senate on November 21, 1969 and December 30, 1969, respectively. We |