The Honorable John Breaux, Senator
SH-503 Hart Senate Office Building
Washington, DC 20510-1803

Dear Senator Breaux:

The American Society of Safety Engineers (ASSE) is pleased to comment on your recently proposed legislation (S.598 and H.R.1241), requiring the U.S. Occupational Safety and Health Administration's (OSHA) to promulgate an ergonomics standard two years after enactment of the subject legislation.

Since ASSE, through Sarah Lyons Walter and Stephanie Leger, already enjoys a professional relationship with you, we will forego an introduction and instead enclose a fact sheet on the Society. However, we would like to point out that ASSE, founded in 1911, and now with almost 33,000 members, is the world's oldest, largest, and most diverse society of safety professionals. In addition, Louisiana is important for ASSE since it has six chapters and almost 1,000 members in the state, which are your constituents.

As you are aware, a significant number of our members have interest in ergonomics. We see the goals of the legislation falling 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 WMSDs (workplace muscular skeletal disorder) in the workplace. ASSE knows that effective ergonomic programs are a significant economic plus to any company or organization. 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 has expressed its interest in working with Labor Secretary Elaine Chao, Congress, OSHA, and all interested parties to craft a new regulation that will protect workers without adding unnecessary regulatory requirements. The Society believes that good public policy, science, and sound technology will drive the process. As for the standard recently overturned, ASSE commented extensively on the original OSHA proposals, 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. which offered 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 for your review. Also attached is the ASSE overall position statement on ergonomics, including our summary views on a potential standard as follows:

• ASSE supports the development of a stand-alone ergonomic standard. This standard should be performance oriented. It should be applicable to all employers and employees and describe the basic tenets and acceptable practices necessary for successfully developing and managing an effective ergonomic program. The standard needs to be supported by cohesive outreach efforts, 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 significant 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 are not a burden to employers when compared to other safety and health compliance requirements. In fact, most efficient and effective ergonomic initiatives will usually "dovetail" with other existing safety and health programs.

• ASSE believes there is science justifying the creation of such a standard. ASSE accepts that the recent National Academy of Science (NAS) ergonomics study indicating a scientific basis for an ergonomic standard. However, ASSE supports enhancing the knowledge base through continued research into the causation, identification, and prevention of ergonomic injuries.

We thank you for your attention to this matter, and if we can be of assistance please feel free to contact the Society.

Sincerely yours,

Samuel J. Gualardo, CSP Society President, 2000-2001

Copy To: ASSE Board of Directors
ASSE Council on Professional Affairs
ASSE Governmental Affairs Committee
ASSE Contact List

Encl ASSE Fact Sheet and Society Materials
ASSE Ergonomic Position Statement
ASSE 3/2000 Comment to OSHA Addressing Ergonomics

April 26, 2001

The Honorable Chris John
1504 Longworth House Office Building
Washington, DC 20515-1807

Dear Congressman John:

The American Society of Safety Engineers (ASSE) is pleased to comment on your recently proposed legislation (S.598 and H.R.1241), requiring the U.S. Occupational Safety and Health Administration's (OSHA) to promulgate an ergonomics standard two years after enactment of the subject legislation.

Since ASSE, through Gordon Taylor and Vera LeBrun, already enjoys a professional relationship with you, we will forego an introduction and instead enclose a fact sheet on the Society. However, we would like to point out that ASSE, founded in 1911, and now with almost 33,000 members, is the world's oldest, largest, and most diverse society of safety professionals. In addition, Louisiana is important for ASSE since it has six chapters and almost 1,000 members in the state. This would specifically include our chapters in Lake Charles and Lafayette, where hundreds of our members are also your constituents.

As you are aware, a significant number of our members have interest in ergonomics. We see the goals of the legislation falling 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 WMSDs (workplace muscular skeletal disorder) in the workplace. ASSE knows that effective ergonomic programs are a significant economic plus to any company or organization. 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 has expressed its interest in working with Labor Secretary Elaine Chao, Congress, OSHA, and all interested parties to craft a new regulation that will protect workers without adding unnecessary regulatory requirements. The Society believes that good public policy, science, and sound technology will drive the process. As for the standard recently overturned, ASSE commented extensively on the original OSHA proposals, 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. which offered 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 for your review. Also attached is the ASSE overall position statement on ergonomics, including our summary views on a potential standard as follows:

• ASSE supports the development of a stand-alone ergonomic standard. This standard should be performance oriented. It should be applicable to all employers and employees and describe the basic tenets and acceptable practices necessary for successfully developing and managing an effective ergonomic program. The standard needs to be supported by cohesive outreach efforts, 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 significant 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 are not a burden to employers when compared to other safety and health compliance requirements. In fact, most efficient and effective ergonomic initiatives will usually "dovetail" with other existing safety and health programs.

• ASSE believes there is science justifying the creation of such a standard. ASSE accepts that the recent National Academy of Science (NAS) ergonomics study indicating a scientific basis for an ergonomic standard. However, ASSE supports enhancing the knowledge base through continued research into the causation, identification, and prevention of ergonomic injuries.

We thank you for your attention to this matter, and if we can be of assistance please feel free to contact the Society.

Sincerely yours,

Samuel J. Gualardo, CSP
Society President, 2000-2001

Copy To:

ASSE Board of Directors
ASSE Council on Professional Affairs
ASSE Governmental Affairs Committee
ASSE Louisiana Chapters
ASSE Contact List

Encl ASSE Fact Sheet and Society Materials
ASSE Ergonomic Position Statement
ASSE 3/2000 Comment to OSHA Addressing Ergonomics