American Society of Safety Engineers
Ergonomics Task Force
Comment and Proposal
National Advisory Committee on Ergonomics
May 1, 2004
The American Society of Safety Engineers (ASSE) recognizes that work-related musculoskeletal disorders (WRMSD) constitute a significant percentage of lost-time workplace injuries in a variety of industries and occupations. ASSE supports the establishment of a federal ergonomics standard that is performance-based and encourages employers, employees and government authorities to mitigate these exposures. Until such a standard can be established, ASSE supports the current approach of the Occupational Safety and Health Administration (OSHA) to establish voluntary ergonomics guidelines, coupled with employer responsibilities under the General Duty Clause and other regulations, in order to reduce the risk of workplace “ergonomic injuries.”
ASSE also supports the leadership of safety professionals and employers who take a “best practices” approach toward preventing these injuries using scientifically sound or promising means. ASSE members work in a widest possible variety of industry types and organization sizes. They understand that ergonomics is not a “one-size-fits-all” proposition. One category or style of ergonomics program may not fit all situations, and often more than one solution exists for any ergonomics-related exposure.
To help advance this nation's commitment to ergonomics, ASSE's Ergonomics Task Force has identified three key areas of information that any size or type of organization, working with staff with a basic understanding of workplace ergonomics and risk control, needs in order to implement an effective ergonomic program under the current approach:
1. Consistent Definitions . Consistent definitions and terminology are critical for companies to communicate internally and with their peers as well as to be able to evaluate studies and control options. Beginning with setting accepted descriptions of injury types – repetitive stress injuries (RSI), cumulative trauma disorder (CTD), and WRMSD for example -- as well as clear definitions of specific risk factors (repetition, et. al.) and their units of measure, the establishment of a uniform language that can be accepted nationally is needed.
Since the loss of momentum in the ANSI Z-365 standards effort, ASSE's Ergonomics Task Force suggests that a laudable legacy of NACE's activities would be the establishment of a stakeholder consensus-building effort on uniform ergonomics terminology, whether through the creation of a terminology sub-committee or task force that continues NACE's efforts under OSHA's purview or through a new stakeholders effort under the auspices of the National Institute for Occupational Safety and Health (NIOSH).
2. Cost/Benefit Evaluation Tools . In the absence of prescriptive regulations, companies need accurate financial information to assist in their cost/benefit evaluation for implementing ergonomic improvements. This is often referred to as “the business case for ergonomics.” Even when it is clear that an improvement or control is needed, the ready availability of this type of information could provide employers with the ability to make the most effective choices between several options and encourage taking ergonomic risks into consideration when making business decisions.
While a number of models for evaluating project costs exist, such as net present value (NPV) and return on investment (ROI), these often rely on direct injury costs saved when applied to safety expenditures. Since smaller organizations may not have sufficient numbers of employees to make these numbers statistically meaningful, a set of tools or models is needed to assist them by including potential indirect costs and benefits, as well as incorporating statistics based upon their industry and task types from a pool standpoint.
Providing such models to companies would allow them to choose those elements that are meaningful to them in making ergonomic improvements or in choosing between alternatives. Elements could include expected or potential changes in productivity, quality, scrap, training, turnover, percent population capable, and product turnaround time as a result of the ergonomic improvement, along with more traditional measures such as direct and indirect injury, workers compensation, or lost work time costs.
It is believed that a number of organizations have partial, informal, or internal models that they use, and that some references to such were made in the public comment preceding the 2000 federal OSHA ergonomic proposed regulations.
With the support of NACE, the ASSE Ergonomics Task Force would like to partner with a leading educational program in occupational safety and health to establish a collection point for organizations and individuals willing to share such models. Common elements of these models would be made available on the web sites of ASSE and the educational program with links to key government safety agency web sites for the review, use, and benefit of others, without endorsement. This collection, along with a literature review, could serve to encourage the development of further refined tools. With wide spread availability of such information, companies and others could more easily evaluate the long term benefits of proposed ergonomic and safety improvements and make appropriate choices.
3. Directory of Existing Standards . Under the current voluntary approach to ergonomics, companies seeking a best practices approach need clear information on existing voluntary consensus guidelines, recommendations, and standards. In order to avoid a so-called “patchwork” of standards or regulations, companies are often interested in knowing about international standards and guidelines as well as guidelines established by other industries, in order to take a global approach.
This effort can be especially confusing, expensive, and difficult for smaller companies due to the large number and variety of recognized organizations such as the American National Standards Institute (ANSI), the American Society for Testing and Materials (ASTM), and International Organization for Standardization (ISO) that issue standards and guidelines, including industry guidelines and recommended practices.
ASSE has established a resource page on it's website ( http://www.asse.org/ ) that lists some of these standards. The ASSE Ergonomics Task Force , again in partnership with a leading educational institution in safety and health, would like to expand this effort by soliciting and compiling input of additional ergonomics related standards and regulations and making these available in one identifiable place with, again, links to federal safety agencies. The prominence of NACE would be a key asset in encouraging individuals and organizations to bring such standards to our attention.This directory would eliminate the duplication of effort by many organizations and provide a valuable reference resource for companies researching existing guidelines and in creating their own, voluntary programs, without endorsing or requiring compliance with any particular standard or guideline.
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