Workers’ Compensation Insurance Rating Bureau of California ® Workers’ Compensation Insurance Rating Bureau of California Report on Electrical Apparatus and Electric Appliance Manufacturing Excerpt from the WCIRB Classification and Rating Committee Minutes October 22, 2013 About this Report The WCIRB prepares and presents reports to the WCIRB’s Classification and Rating Committee to assist in the formulation of proposed changes to the Insurance Commissioner’s regulations. Once adopted by the Classification and Rating Committee, the recommendations contained in the report are provided to the WCIRB Governing Committee and may be included in a WCIRB regulatory filing that is submitted to the Insurance Commissioner for approval. About the WCIRB The WCIRB is California's trusted, objective provider of actuarially-based information and research, advisory pure premium rates, and educational services integral to a healthy workers' compensation system. Learn more at www.wcirb.com. 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To seek permission to use any of the WCIRB Marks or any copyrighted material, please contact the Workers’ Compensation Insurance Rating Bureau of California, 525 Market Street, Suite 800, San Francisco, California 94105-2767. Released: November 11, 2013 Report on Electrical Apparatus and Electric Appliance Manufacturing 3179, Electrical Apparatus Mfg. – N.O.C. 3570, Electric Appliance Mfg. – N.O.C. Executive Summary Objective Pursuant to a directive from the Classification and Rating Committee, the WCIRB is reviewing all instances wherein the experience of two or more classifications is combined for experience rating purposes. As part of this review, the WCIRB reviewed the current procedure of combining, for ratemaking purposes, the experience of Classifications 3179, Electrical Apparatus Mfg., and 3570, Electric Appliance Mfg., to determine whether to continue the long-standing procedure of combining the experience of these classifications for ratemaking purposes. Findings Based on its review, the WCIRB has determined that: 1. The operations contemplated by Classification 3179 are separate, distinct and identifiable from those contemplated by Classification 3570; 2. Classifications 3179 and 3570 each develop sufficient data to produce separate, credible advisory pure premium rates; 3. Based on experience at policy year 2014 level, Classification 3179 has a Selected (Unlimited) Loss to Payroll Ratio that is 1.8% less than the current Selected (Unlimited) Loss to Payroll Ratio for Classifications 3179 and 3570 combined; 4. Based on experience at policy year 2014 level, Classification 3570 has a Selected (Unlimited) Loss to Payroll Ratio that is 5% greater than the current Selected (Unlimited) Loss to Payroll Ratio for Classifications 3570 and 3179 combined; and 5. Amendments should be made to Classifications 3179 and 3570 for clarity. Recommendations The WCIRB recommends that the following changes be made effective January 1, 2015: 1. Discontinue the combination of experience of Classifications 3179 and 3570 for ratemaking purposes and allow each classification to develop its own advisory pure premium rate; 2. Amend Classification 3179 to include the manufacture of actuators; and 3. Amend Classification 3570 to include the manufacture of battery chargers and battery pack assemblies. 1 WCIRB California ® Released: November 11, 2013 Introduction The WCIRB reviewed the procedure of combining, for ratemaking purposes, the experience of Classifications 3179, Electrical Apparatus Mfg., and 3570, Electric Appliance Mfg. Typically, classifications are combined for ratemaking purposes for the following reasons: 1. Similarity in Operations Classifications are combined for ratemaking purposes when the proper classification may be difficult to determine due to a significant similarity in operations, for example, a clear delineation does not exist between the two classifications. 2. Low Statistical Credibility The experience of two or more classifications is combined for ratemaking purposes when one or more of the classifications lack statistical credibility. Although the classification(s) may be clearly defined, due to insufficient statistical credibility, the classifications are combined based on similarity in industry type and operations. 3. Temporary Variance in Experience There is a temporary dissimilarity in the relative experience of the two related classifications that results in a relationship between the relativities for the classifications that are not expected to continue into the future. That is, based on historical experience for each classification and other factors, there is a high likelihood that the advisory pure premium rate relativities for the classifications will change. With respect to the combination of experience of Classifications 3179 and 3570, this report focuses on: 1. Whether Classifications 3179 and 3570 describe two separate and distinct industries that would permit, from a classification administration standpoint, the development of accurate advisory pure premium rates. If so, 2. Whether there is sufficient data to produce statistically credible advisory pure premium rates for Classifications 3179 and 3570. Classification History The history of Classifications 3179 and 3570 is as follows: 1915: Originally, all electrical apparatus and component manufacturing was assigned to Classification 3643, Electrical Apparatus Mfg. 1930: Classification 3179, Electrical Apparatus Mfg., was established to specifically address the manufacture and repair of small household-type electrical appliances. Classification 3179 also applied to the manufacture of electrical components, coils, heater elements, connectors, and filters. As technology progressed, electronic elements including resistors, capacitors, relays and coils were assigned to Classification 3179. 1965: Classification 3178, Electronic Element Mfg., was established to apply to the manufacture of electronic elements including, but not limited to resistors, capacitors, relays and coils, previously assigned to Classification 3179. 1996: Classification 3570, Electric Appliance Mfg., was established. Classification 3570 was combined with Classification 3179 for ratemaking purposes to provide rate stability and to monitor the application of each classification. 2 WCIRB California ® Released: November 11, 2013 Description of Operations Following are the classification phraseologies, footnotes and relevant summaries of operations currently assigned to Classifications 3179, Electrical Apparatus Mfg., and 3570, Electric Appliance Mfg. ELECTRICAL APPARATUS MFG. – N.O.C. 3179 Classification 3179 shall not be used for division of payroll in connection with Classifications 3643(1), Electric Power or Transmission Equipment Mfg. – N.O.C., or 3643(2), Electric Control Panel or Switchgear Mfg., unless the operation described by Classification 3179 constitutes a separate and distinct enterprise having no connection with the operations covered by Classifications 3643(1) or 3643(2). This classification contemplates the manufacture or repair of electrical apparatus, including, but not limited to, electrical control and switchboard assemblies with a power rating of less than 746 watts (one horsepower). This classification also includes, but is not limited to, the manufacture of electrical-mechanical components such as solenoids, push button switches and relays. Display and parts departments that are physically separated from the repair shop and sell parts commercially shall be separately classified as 8017(7), Stores – hardware. Classification 3179 is generally applied to the manufacture of an electrical apparatus with a power rating of less than 746 watts (one horsepower). The manufacture of a comparable electrical apparatus having a power rating in excess of one horsepower is assignable to Classification 3643(2), Electrical Control Panel or Switchgear Mfg. Electrical-mechanical apparatus are mechanical components that are controlled by electrical inputs. This includes a variety of apparatuses including, but not limited to, control panels, switchboards assemblies, solenoids, actuators, switches and relays. Controls and switchboards are used to control and regulate various mechanical operations. Electrical controls include junction boxes, switching units, traffic light controls and fuse panels. Control panel fabrication requires the integration of circuitry components, including printed circuit boards, power supplies, switches, relays, wires harnesses, lights, displays and manual controls, into a housing chassis. A solenoid is an electromagnetic device that converts electrical energy into mechanical energy. The electrical energy causes a pin or rod to retract. Solenoids create a magnetic field from an electric current and uses the magnetic field to create linear motion. The manufacture of solenoids involves winding copper wire around a plastic or metal bobbin. The resultant coil is sealed with a liquid insulator and is attached to wire leads. A metal pin or rod is inserted within the core of the bobbin. The assembly is secured within a metal housing to complete. Relays are electrically operated switches. Relays are used to control a circuit by a low-power signal, or where several circuits must be controlled by one signal. Relays usually consist of a coil of wire wrapped around an iron core, a movable iron armature and one or more sets of contacts. It is noted that the manufacture of electronic digital control panels that do not perform an electricalmechanical function are assignable to Classification 3681, Instrument Mfg. – electronic – professional or scientific. ELECTRIC APPLIANCE MFG. — N.O.C. 3570 This classification contemplates, but is not limited to, the manufacture or repair of lighting apparatus, flashlights, heating elements and domestic appliances such as vacuum cleaners, food processors and hair dryers. Display and parts departments that are physically separated from the repair shop and sell parts commercially shall be separately classified as 8017(7), Stores – hardware. Small household appliances are usually labor saving devices used for domestic purposes. This includes, but is not limited to, hair dryers, waffle irons, vacuum cleaners, floor buffing machines, coffee makers, air 3 WCIRB California ® Released: November 11, 2013 purifiers, juice extractors and air ionizers. The fabrication of these products entails assembling switches, motors, fans, wire harnesses, cords and plastic or metal housings, with product specific components to produce the completed product. Electric heating devices include, but are not limited to, food warmers, flexible heater circuits to warm circuitry that is exposed to the elements (including on an aircraft), waterbed heaters, immersion heaters and heater elements used to heat water quickly. The common component to these devices is the heating element. Heating elements produce heat (energy) from the resistance generated when an electric charge is applied to a metal core. Heating elements are constructed from metal tube, roll, coil, bar or wire stock. The stock is machined or rolled as required, insulated and secured to lead wires. The heating element is assembled with electric cords and placed into a housing. Electric lighting products include, but are not limited to, flashlights, automobile headlight assemblies, light ballasts (an electrical device for starting and regulating fluorescent lamps), Christmas tree light sets and interior LED strip lighting. Typical fabrication involves the assembly of switches, light bulbs, light emitting diodes, lens caps, electrical wire, springs and metal or plastic casings. It is not uncommon for lighting product manufacturers to engage in the fabrication of metal or plastic component parts. Classification 3570 contemplates the manufacture of battery pack assemblies that are used to power electronic devices. The fabrication involves soldering metal tab connectors onto batteries, and arranging them into the desired configuration. The assembly is shrink-wrapped in a plastic case. More complex battery pack assemblies involve the integration of electronic circuit boards, wiring, and contacts. The assemblies are placed into purchased plastic or metal housings. Classification Analysis Based on the description of operations provided above, firms assigned to Classification 3179 manufacture devices and components that primarily are used to perform electrical-mechanical functions by converting energy. Firms assigned to Classification 3570 primarily manufacture electric appliances used to perform specific tasks. The WCIRB’s inspection report library shows that the major categories of products assigned to Classification 3179 include control panels and control systems, switches, and actuators. The major categories of products assigned to Classification 3570 include household appliances, lighting and lighting apparatuses, battery chargers and battery pack assemblies, and heaters/heating elements. Household appliances include vacuums, coffee machines, cooling fans, and other domestic equipment. As displayed below, the end products fabricated by both classes are distinct and the functions of the end products are different. 4 WCIRB California ® Released: November 11, 2013 Sample of Electrical Apparatus Contemplated by Classification 3179: Figures 1 & 2: Control panels Figure 3: Solenoids Figure 4: Actuator Electrical Appliances Contemplated by Classification 3570: Figure 5: Vacuums, various home appliances and carpet cleaners Figure 6: Auto headlights, light ballast and led strip lights 5 WCIRB California ® Released: November 11, 2013 Figure 7: Heaters and heating elements Figure 8: Battery charger and battery pack assembly The firms assigned to Classification 3179 typically manufacture an electrical apparatus that is of a much smaller scale when compared to many appliances contemplated by Classification 3570. Control panels, switchboard assemblies, solenoids, switches, and relays will be integrated into a larger system to provide the electrical mechanical functions needed to operate equipment or machinery. Furthermore, these products may also convert the energy required to operate equipment or machinery. Conversely, a majority of the products assigned to Classification 3570 are complete electrical appliances that do not need to be connected to or assembled into equipment or machinery in order to perform its intended function. Classification 3570 also applies to the manufacture of components, which includes heating elements, battery packs, light ballasts, and lighting assemblies. With the exception of battery packs, these components are described in Classification 3570. From a classification standpoint, there appears to be no compelling reason to continue to combine Classifications 3179 and 3570 for ratemaking purposes. To further determine whether a clear line of demarcation exists between Classifications 3179 and 3570, 1 the WCIRB reviewed 2014 policy year Unit Statistical Reports (USR) to determine the number of 1 A USR is a record of the total exposure and the claims pertaining to a policy. At the time this report was prepared, 2010 was the most recent policy year for which complete ratemaking data was available. 6 WCIRB California ® Released: November 11, 2013 employers that reported payroll in both Classifications 3179 and 3570. As shown in Table 1, no employers developed reportable payroll in both classifications. Table 1: 2014 USR Summary – Number of Employers For Which Payroll Was Reported in Classifications 3179 and 3570 Classification Employers with Payroll Reported in Indicated Classification 3179 1,775 0 100% 0% 3570 834 0 100% 0% Employers with Payroll Reported in Both Classifications Percent – Payroll only Reported in Indicated Classification Percent – Payroll Reported in Both Classifications In a similar manner, staff determined the number of inspection reports that assign Classifications 3179 and 3570. Table 2: Number of WCIRB Inspection Reports That Assign Classifications 3179 and 3570 Classification Employers Assigned to Indicated Classification 3179 629 4 99.3% 0.7% 3570 378 4 98.9% 1.1% Employers Assigned to Both Classifications Percent – Employers Assigned only to Indicated Classification Percent – Employers Assigned to Both Classifications As noted above, very few employers have been assigned to both Classifications 3179 and 3570. This information indicates that the two industries have little commonality in operations. Each classification is clearly defined and the potential for misclassification of payroll is low. Therefore, from a classification perspective, there appears to be no compelling reason to continue to combine Classifications 3179 and 3570 for ratemaking purposes. Accordingly, staff reviewed the payroll and loss data developed by each group of employers to determine (1) if sufficient data is developed to produce credible advisory pure premium rates for each group, and if so, (2) the impact on employers assigned to Classifications 3179 and 3570 that would result if unique pure premium rates are promulgated for each group. Statistical Analysis Table 3 presents the classification relativity data for Classification 3179 and 3570 combined at policy year 2014 level: 7 WCIRB California ® Released: November 11, 2013 Table 3: Electrical Apparatus Mfg. (3179) and Electrical Appliance Mfg. (3750) Classification Relativity Data at Policy Year 2014 Level Year Number of Unit Statistical Reports Payroll Losses Loss to Payroll Ratio 2009 486 425,806,819 15,258,109 3.583 2010 505 547,995,082 17,374,320 3.171 973,801,901 32,632,429 Total Selected (Unlimited) Loss to Payroll Ratio 4.180 Credibility2 Indemnity Medical 1.00 1.00 Tables 4 and 5 present the classification relativity data at policy year 2014 level for each classification independently: Table 4: Electrical Apparatus Mfg. (3179) Classification Relativity Data at Policy Year 2014 Level Year Number of Unit Statistical Reports Payroll Losses Loss to Payroll Ratio 2009 324 347,360,882 12,724,695 3.663 2010 336 455,045,647 13,718,284 3.015 802,406,529 26,442,979 Total Selected (Unlimited) Loss to Payroll Ratio 4.106 Credibility Indemnity Medical 1.00 1.00 Table 5: Electric Appliance Mfg. (3570) 2 The relativity for each classification in the upcoming policy year is determined based on a comparison of that classification’s actual losses per $100 of payroll and the ratio of losses per $100 of payroll underlying the current pure premium rate. The ”credibilities” assigned to a classification are the statistical weights assigned to that classification’s experience as a predictor of future claim experience relative to the loss per $100 of payroll underlying the classification’s current pure premium rate. The predictability or credibilities assigned to a classification’s recent historical experience depends on the volume of indemnity and medical claims incurred during the experience period. The WCIRB strives to have classifications that are fully, or 100%, statistically credible based on historical experience over five or fewer years, which mean that the classification’s relativity in the upcoming policy year can be best, estimated using only the loss per $100 of payroll experience from the latest two-, three-, four- or five-year periods. The WCIRB generally will not recommend the establishment of a new classification if the credibility factors are less than one-half (< 0.50). 8 WCIRB California ® Released: November 11, 2013 Classification Relativity Data at Policy Year 2014 Level Year Number of Unit Statistical Reports Payroll Losses Loss to Payroll Ratio 2006 173 76,683,178 2,068,366 2.697 2007 167 82,711,760 2,954,008 3.571 2008 163 84,053,341 3,383,130 4.025 2009 162 78,445,937 2,533,414 3.230 2010 169 92,949,435 3,656,036 3.933 414,843,651 14,594,953 Total Selected (Unlimited) Loss to Payroll Ratio Indemnity Medical 0.81 0.85 4.390 As shown above, Classifications 3179 and 3570 develop sufficient payroll and loss data to produce credible advisory pure premium rates. Therefore, from a ratemaking perspective, there appears to be no compelling reason to continue to combine Classifications 3179 and 3570 for ratemaking purposes. Impact Analysis For information purposes, Tables 6 and 7 depict the impact on affected policyholders if separate classification relativities – and thus advisory pure premium rates – are established for Classifications 3179 and 3570. Table 6: Classifications 3179 and 3570 Combined vs. Classification 3179 Comparison of Selected (Unlimited) Loss to Payroll Ratios at Policy Year 2014 Level Classifications 3179 and 3570 Classification 3179 Difference 4.180 4.106 -0.074 (-1.8%) Table 7: Classifications 3179 and 3570 Combined vs. Classification 3570 Comparison of Selected (Unlimited) Loss to Payroll Ratios at Policy Year 2014 Level Classifications 3179 and 3570 Classification 3570 Difference 4.180 4.390 +0.21 (+5.0%) Based on experience at policy year 2014 level, Classification 3179 has a Selected (Unlimited) Loss to Payroll Ratio that is 1.8% less than the Selected (Unlimited) Loss to Payroll Ratio for Classifications 3179 and 3570 combined; and Classification 3570 has a Selected (Unlimited) Loss to Payroll Ratio that is 5% greater than the Selected (Unlimited) Loss to Payroll Ratio for Classifications 3179 and 3570 combined. Accordingly, if each classification developed unique advisory pure premium rates based on its own payroll 9 WCIRB California ® Released: November 11, 2013 and loss data at policy year 2014 level, the unique advisory pure premium rate for Classification 3179 would be 1.8% lower than the combined rate, and the unique advisory pure premium rate for Classification 3570 would be 5.0% higher than the combined rate. Conclusion Based on its review of the procedure of combining Classifications 3179 and 3570 for ratemaking purposes, the WCIRB finds that: 1. The operations contemplated by Classification 3179 are separate, distinct and identifiable from those contemplated by Classification 3570; 2. Classifications 3179 and 3570 each develop sufficient data to produce credible advisory pure premium rates; 3. Based on experience at policy year 2014 level, Classification 3179 has a Selected (Unlimited) Loss to Payroll Ratio that is 1.8% less than the current Selected (Unlimited) Loss to Payroll Ratio for Classifications 3179 and 3570 combined; 4. Based on experience at policy year 2014 level, Classification 3570 has a Selected (Unlimited) Loss to Payroll Ratio that is 5% greater than the current Selected (Unlimited) Loss to Payroll Ratio for Classifications 3179 and 3570 combined; and 6. Amendments should be made to Classifications 3179 and 3570 for clarity. Recommendations The WCIRB recommends that the following changes be made effective January 1, 2015: 1. Discontinue the combination of experience of Classifications 3179 and 3570 for ratemaking purposes and allow each classification to develop its own advisory pure premium rate; 2. Amend Classification 3179 to include the manufacture of actuators; and 3. Amend Classification 3570 to include the manufacture of battery chargers and battery pack assemblies. 10 WCIRB California ® Released: November 11, 2013 Recommendation Amend Classification 3179, Electrical Apparatus Mfg., within the Electronics Industry Group, to include the manufacture of actuators. PROPOSED ELECTRONICS INDUSTRY ELECTRICAL APPARATUS MFG. — N.O.C. 3179 Classification 3179 shall not be used for division of payroll in connection with Classifications 3643(1), Electric Power or Transmission Equipment Mfg. – N.O.C., or 3643(2), Electric Control Panel or Switchgear Mfg., unless the operation described by Classification 3179 constitutes a separate and distinct enterprise having no connection with the operations covered by Classifications 3643(1) or 3643(2). This classification contemplates the manufacture or repair of electrical apparatus, including, but not limited to, electrical control and switchboard assemblies with a power rating of less than 746 watts (one horsepower). This classification also includes, but is not limited to, the manufacture of electrical-mechanical components such as solenoids, push button switches, actuators and relays. Display and parts departments that are physically separated from the repair shop and sell parts commercially shall be separately classified as 8017(7), Stores – hardware. * * * * * * * Recommendation Amend Classification 3570, Electric Appliance Mfg., to include the manufacture of battery chargers and battery pack assemblies. PROPOSED ELECTRIC APPLIANCE MFG. – N.O.C. 3570 This classification contemplates, but is not limited to, the manufacture or repair of lighting apparatus, flashlights, heating elements, battery chargers, battery pack assemblies and domestic appliances such as vacuum cleaners, food processors and hair dryers. Display and parts departments that are physically separated from the repair shop and sell parts commercially shall be separately classified as 8017(7), Stores – hardware. 11 WCIRB California ® 525 Market Street, Suite 800 San Francisco, CA 94105-2767 Voice 415.777.0777 Fax 415.778.7007 www.wcirb.com wcirb@wcirb.com