On the Matter of:

U.S. Department of Labor Public Forum About Ergonomics

Presented by

M.E. "Eddie" Greer, CSP President, 2001-2002

July 17, 2001

Good afternoon, my name is Eddie Greer. I am a Certified Safety Professional (CSP), and have the distinct honor and privilege of serving as President of the American Society of Safety Engineers (ASSE) for 2001 to 2002.

The American Society of Safety Engineers (ASSE) is the oldest and largest society of safety professionals in the world. Founded in 1911, ASSE represents 33,000 dedicated safety professionals. ASSE also serves as secretariat of eight (8) American National Standards Committees, making the Society the largest holder of safety/health standards projects. In addition, we have over forty (40) safety professionals/ASSE representatives serving on various ANSI, NFPA, ASME, and ASTM committees. ASSE has been dedicated to the protection of people, property, and the environment for ninety years and our members are proud of the accomplishments we have made in safeguarding workplaces for the American worker.

We commend the Department of Labor for hosting this public forum about ergonomics. As you are aware from our past interaction, a significant number of our members have interest in ergonomics. The goals of these initiatives fall into the ASSE mission of protecting people, property, and the environment. ASSE members continue to work with employers, employees, clients, associates, and other safety professionals to prevent workplace musculoskeletal disorders. We are dedicated to enhancing safety in the workplace and are committed to showing that effective overall safety and health programs, including ergonomics, will positively impact an organization's bottom-line.

ASSE continues to express its interest in working with Labor Secretary Elaine Chao, Congress, OSHA, and all interested parties to craft new ergonomic initiatives that will protect workers without adding unnecessary regulatory requirements. The Society believes that science, and sound technology must drive this process to develop the best public policy.

As for the standard recently overturned, ASSE commented extensively on the original OSHA proposal, the working drafts, and the rule proposed in the Federal Register. Our comments were based on widespread member consensus representing good science and sound technology. In addition, ASSE was the only professional group in the U.S. to offer a counter-proposal draft standard to OSHA. These materials can still be used as guidance documents for the public policy making process. Accordingly we include them again as part of the record of these proceedings for your review.

The Society believes there is not a one-size-fits-all approach to ergonomics. Control measures should be designed to eliminate ergonomic stressors specific to the results of the ergonomic evaluation and provide for effective follow-up mechanisms. Safety and health professionals, ergonomists, engineers, and other trained specialists can provide valuable assistance in various aspects of the improvement process.

ASSE strongly believes that research should continue in both the public and private sectors. Public sector agencies, such as the National Institute for Occupational Safety and Health (NIOSH), should continue researching ergonomic related issues and identifying sound hazard control mechanisms.

Since the results of this public forum will apparently be used to decide on a possible course of action regarding Federal rulemaking, ASSE believes it appropriate to specifically comment on a potential standard. ASSE has historically recommended that any ergonomics standard:

  • Be performance based and not use a one-size-fits-all approach to ergonomics.

  • Require an ergonomic evaluation, and performed by a person competent in ergonomic-related issues. This concept is vital for larger organizations and employers with significant hazards and exposures. Any guideline or standard must contain sufficient information to allow the very small employer to complete accurate self-analysis of their ergonomic hazards and exposures.

  • The issue of a trigger mechanism needs to be part of the public debate. The goal of any DoL/OSHA standard is to prevent injury, illness, and fatality, and not allow an incident to take place before eliminating hazards.

  • Ensure that any proposed standard does not encroach upon existing state worker compensation systems and does not address issues outside the scope of occupational safety and health.

  • Emphasis should be placed on improvement versus overly detailed specifications. Safety and health professionals, ergonomists, engineers, and other trained specialists can provide valuable assistance in the evaluation process.

  • Be created through private/public sector partnership, such as the negotiated rulemaking process, or the multiple stakeholders input process as exemplified by metalworking fluids or the proposed silica rulemaking.

With respect to the specific questions asked by OSHA in the June 12, 2001 Federal Register announcement, ASSE offers the following:

1. What is an ergonomic injury?

After reading the Federal Register notice, we did some basic research on this issue and an Internet search alone yielded at least two hundred different definitions. It almost seems as if we are using the "Field of Dreams" approach to ergonomics with this question. Hopefully you remember that film starring Kevin Kostner where he builds a ball field in an Iowa cornfield with the mythical promise that "if you build it - they will come". In some ways, the ending of the film, is almost identical to what is happening here. Instead of a line of cars coming to the field to play ball at the end of the movie, we now have thousands of safety, health, and environmental professionals, lining up in the bullpen trying to get their definitions up on the pitchers mound.

Perhaps the best definition we know of, and it does fly right over home plate, comes from one of our own publications, edited by Richard Lack titled: The Dictionary of Terms Used in the Safety Profession. The definition is as follows:

Ergonomic Disorder: Any musculoskeletal or nervous system disorder affecting a person's upper or lower extremities or lower torso. Such a disorder may be caused or aggravated by repetitive motions, forceful exertions, vibration, sustained or awkward positions, or compression of a hand, wrist, arm, shoulder, neck, back, or leg over an extended period.

Another well known and accepted definition can be found in Bernardino Ramazzini's, Diseases of Tradesmen, which was written circa 1700. There have been different variations of the definition, but the one we see most often is: An ergonomic injury is the insidious and subtle cumulative affects of certain excessive, violent, disorderly motions and improper postures of the body that accrues to workers from the exercise of their respective trades, and non-work activities and environmental conditions.

In the view of most safety professionals, "ergonomic injuries" basically involve stressing of soft tissue, also commonly known as strains and/or sprains. It is important that any definition recognized at the Federal level ensure that the issue of soft tissue injury be included and that ergonomic injuries require safety related countermeasures and not those actions commonly found in the public health model.

One of the biggest issues we have continued to address for years is the perception that ergonomics is a health-related discipline. It is important to know that soft tissue injuries have historically been addressed through countermeasures developed by safety professionals using their preventative model and not through models used to prevent traditional diseases.

2. How can OSHA, employers and employees determine whether an ergonomics injury is on the job or off the job.

We suggest the answer can be found in OSHA's proposal for Injury and Illness Recording and Reporting Standard, Federal Register, February 2, 1996, 29 CFR 1904 and 1952, page 4404, there is an Alternative #2 titled: Limit to Predominant Workplace Linkage. This section focused on work relationship issues beyond ergonomics or strains and sprains, but the concept is important and should be considered by the Department of Labor as an approach to this issue. It included a form that might be used to make such decisions. Our recommendation is that the DoL review what has already been proposed, and utilize what is already in existence. However, we commend OSHA for asking this question since we see it as the key issue impacting any standard, guideline, outreach initiative, or consultation program. The goal of the safety professional is to evaluate and judge workplace ergonomic hazards and exposures. When such hazards and exposures are identified, it necessitates employer action. But, as ASSE has now been pointing out publicly for almost ten years, one of the keys to OSHA being successful in the ergonomics arena is to avoid requiring employers to address cases that are not job related.

A person's individual response to the stressors of excessive, violent, disorderly motions and improper postures of the body is influenced by variety of environmental factors including an individual's physical and emotional health. People working side-by-side at the identical work task labor differently and bring individual factors into the equation e.g., age, weights, strength, outside activities, and many more. It is critical that we accept and realize this fact, which is why ASSE continues to point out that there is not a "one size fits all" approach to effective ergonomic programs.

3. What is the most useful and cost-effective type of government involvement to address workplace ergonomics?

From the perspective of cost effectiveness and public policy, our recommendation is that we need to proceed in an incremental manner. As we have recommended before, a good course of action would be to review the Red Meat Handling Guidelines and publish a similar document for general industry. This would enable the Department of Labor to get something out to general industry and establish some basic operating guidelines for our members to consider implementing in the workplace. At the very least, it assists those employers and organizations not having any ergonomic programs in place.

However, ASSE believes the issue really at debate in this public forum is if OSHA should attempt another initiative to create ergonomics standard. ASSE accepts the findings of the National Academy of Science (NAS) ergonomics study, and believes it indicates a basis for an ergonomic standard.

Regarding the issue of cost effectiveness, if OSHA develops a stand-alone ergonomic standard, it needs to be supported by a cohesive outreach effort melding the resources of OSHA, business associations, professional societies and academia. Such a program can be supported by other positive reinforcement actions such as penalty reductions for good faith efforts by employers; or, because of the anticipated costs to employers, granting tax credits for the creation/maintenance of an acceptable program.

The establishment of basic ergonomic management programs and increasing employee awareness and involvement on these issues is a sound investment for employers. Perhaps one of our biggest concerns has been the perception by those in the public or private sector that ergonomics not part of existing safety, health, and environmental programs, that it somehow is a separate discipline. In fact, most efficient and effective ergonomic initiatives must "dovetail" with other existing safety and health programs, and the rule, regulation, or guideline needs to recognize and accommodate such dovetailing. Whether OSHA develops a standard or a guideline, both the public and private sector must realize that compliance with the law is only one component of an effective and efficient safety, health, and environmental program.

All of these activities have triggered a need for trained safety professionals. However, ASSE is concerned that OSHA still fails to recognize the importance of using competent safety and health professionals and qualified consultants to conduct or direct ergonomic programs. OSHA should encourage employers to use staff safety professionals, or contract with those safety professionals who have the competence and expertise to conduct ergonomic-related activities.

In summary, ASSE's overall experience with ergonomics management practices has illustrated positively its very effective uses to protect the nation's workforce and secure the corporate well being. ASSE stands ready to work with the Agency to address ergonomic injuries and create outreach, training, and consultation programs, which are technically and professionally feasible.

I thank you for your time today and would be pleased to answer any questions that you may have.


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