ASSE members have significant interest in the ergonomic standards proposed by OSHA

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An Interview with DR. Linda Rosenstock of the National Institute for Occupational Safety and Health (NIOSH)


Introduction

The Society is dedicating itself to bringing the membership more cutting edge information from agencies such as OSHA, NIOSH, MSHA, and EPA. Representatives of the ASSE Governmental Affairs Committee (GAC) had the opportunity to meet with Dr. Linda Rosenstock of the National Institute for Occupational Safety and Health (NIOSH) to discuss cutting edge safety and health issues. There appears to be a great deal of interest in NIOSH activities, thus, one of our proposals was to do an interview with Dr. Rosenstock on NIOSH activities for the Journal. Dr. Rosenstock agreed to do an interview for Professional Safety Journal, and the highlights of this interview were published in the 12/98 and 1/99 issue of the Journal. The interview is as follows:

ASSE: Ergonomics continues to be a hot issue, and NIOSH is in the middle of the debate. It is no secret that there is significant resistance to OSHA promulgating a standard on ergonomics. Why do you think there continues to be such apprehension and resistance? How can a research entity such as NIOSH help end the ongoing debate?

Rosenstock: There are strong feelings on this issue because of its magnitude. To the extent that the debate involves issues of science, NIOSH has a vital role. We have the responsibility to communicate accurate and useful scientific information, and to advance further research in areas where legitimate uncertainties remain.

From the evidence, we know that a consistent relationship exists between work-related physical factors and musculoskeletal disorders, especially at higher exposure levels, as we documented last year in our comprehensive analysis of the epidemiological literature. From more than two decades of research and technical assistance, we also know there are practical ways to identify, correct, and prevent such disorders. We compiled examples of such approaches in our primer, "Elements of Ergonomics Programs", which was our most requested publication last year.

Building on those foundations, we can continue our leadership by conducting, funding, and partnering with others on studies that will give us further answers C for example, what gaps in information remain? What engineering solutions are most effective? How well are existing programs working?

ASSE: One of the big areas of the debate surrounding ergonomics is the actual depth of the ergonomics problem in the United States. If we remove back injuries from the debate - how severe is the ergonomics issue in the United States? How do we stack up against other industrialized countries?

Rosenstock: By any measure, whether citing estimates from the Bureau of Labor Statistics (BLS), occupational surveillance studies, or state workers' compensation data, the problem is large in both health and economic terms. According to the most recent BLS data, 281,000 disorders involving repetitive trauma of the upper extremities were reported in 1996, and that figure is widely recognized to be an underestimate. Costs for such disorders have been estimated from about $8,000 per case on average, according to data from Liberty Mutual Insurance, to about $21,000 per case as estimated by the California Workers Compensation Institute. So the problem of upper extremities is a major one C which is not to underestimate the importance of low-back disorders, which account for 16 percent of all workers' compensation claims. In combination, low-back and upper-extremity disorders are the single largest cause of lost work days.

World-wide, musculoskeletal disorders also have significant impact. For example, available data show that almost 3 percent of the Finnish population age 18 to 64 years old were receiving early pensions in 1992 from musculoskeletal disorders, the leading cause being back injury. Our fellow industrialized countries have recognized this problem, and several European directives and standards set requirements to prevent musculoskeletal disorders through changes in the work environment, tools, and work performance. Although not well measured, these disorders are also seen as major problems for workers in the developing world.

ASSE: The Society raised concerns during past Hill meetings, with different legislators, that the NAS (National Academy of Sciences) study on ergonomics is not needed. Our concern is not with the merit of studying the problem of ergonomics, but rather that this project is duplicative of the recently released NIOSH findings, and may be viewed as a delaying tactic with political implications. Our position is that the OSHA Act created a research body (NIOSH) to conduct such activities. Can you comment on this, and if you can, what are your thoughts?

Rosenstock: I agree with your concerns. NIOSH's comprehensive review of the epidemiological literature pertaining to work-related musculoskeltal disorders has been widely recognized by the research community outside NIOSH for its rigorous methodology and its scientific quality. It received the most extensive outside scientific review of any document in NIOSH's history. Rather than going over well-established ground, it would be more useful to move on and address areas where further data truly are needed. The National Occupational Research Agenda (NORA), which identifies 21 priority areas where national research will be critical for protecting workers from injury and illness in the coming decade, is a key vehicle for furthering those types of studies.

ASSE: What are your thoughts on additional legislative proposals to create scientific panels appointed by NAS to review proposed safety and health rules to ensure they are based on good science and technology? It is most commonly called peer review. From face value peer review sounds like a reasonable idea, but ASSE has questioned whether this just puts another obstacle into efficient and effective safety and health rule making. ASSE has also commented that this study, if conducted, should be performed by NIOSH. Does NIOSH have the resources to become involved in a peer review process if it were to ever by codified?

Rosenstock: I will defer part of your question to OSHA, but as I mentioned previously, we are concerned about any proposal that would replicate the work that NIOSH already does and does well, as is the case with proposals involving further review of the scientific evidence for musculoskeletal disorders.

ASSE: ASSE has dedicated itself to ensuring that federal agencies maintaining a national focus on the importance of safety and health have the resources to efficiently meet their objectives. What is the current appropriations situation for NIOSH? What can safety professionals do to ensure that NIOSH remains a viable research entity?

Rosenstock: The appropriations process for FY 1999 is still under way at the time of this interview. At this stage, the House and the Senate respectively have recommended levels of $185.8 million and $200 million. The House figure is 1 percent below our FY 1998 operating level, and the Senate figure is 6.8 percent above. I am hopeful that Congress will acknowledge the important work of NIOSH and its partners, particularly the great strides we have made under NORA, and provide at least the increase proposed by the Senate.

But it is important to note that, through the >80s and into the >90s, we have worked under a budget that pales in comparison with the magnitude of the problems we are grappling with. Our resources have shrunk by about 25 percent since 1980 in actual purchasing power. In general, our diverse partners work under similar constraints. This situation points up the need for NORA as a national vehicle for working together to leverage these scarce resources to achieve things that none of us can do alone. The interest and help of the professional safety discipline is vital for this effort. The NORA priorities were developed with input from more than 500 outside groups and individuals, many of them from the professional safety community. One of our implementation teams is the traumatic injury research team, whose membership includes a past president of ASSE. Safety professionals also have a vital role in collaborating with us on research, such as studies to identify workplaces where we can evaluate the effectiveness of proposed intervention strategies in actual work situations. The recent report from the traumatic injury research team can be valuable for identifying issues and priorities for collaborative efforts.

ASSE: The National Safety Council, as secretariat of ANSI Z365 (American National Standard Institute) has just published a draft voluntary national consensus standard addressing cumulative trauma disorders. We expect that there will be a lot of public comment on this draft. What are some of the positives and negatives you see in Z365 from the perspective of the research conducted by NIOSH?

Rosenstock: The ANSI Z365 draft standard shows that results of research can be incorporated into the public policy process, and can be useful in that process. The draft standard also demonstrates that although some gaps exist in the research, sufficient knowledge exists to suggest solutions.

ASSE: What about more outreach by NIOSH? It seems that one of NIOSH's biggest issues has been the aspect of not receiving enough positive publicity. Many ASSE members comment that NIOSH concentrates on health related issues at the expense of safety. Do you see any merit in this argument? What are your personal viewpoints?

Rosenstock: When I accepted the directorship of NIOSH, one of my primary goals was to heighten public recognition of the agency and its valuable work. We have taken great strides to make our information known and useful, and to seek broad, timely news media coverage of new reports, publications, and research findings. Our toll-free information number (1-800-35-NIOSH), which offers easy, immediate access to our resources, received nearly 100,000 calls in 1997. Our home page on the World Wide Web at www.cdc.gov/niosh features the full text of major NIOSH documents and other links. We maintain an active exhibit program at professional meetings and conferences, giving us an opportunity to receive direct feedback from users. Through videos, CD-ROMs, and other electronic products, we are meeting demands for information in new, non-print formats. One upcoming video will highlight the importance of our workplace safety research by describing our Fatality Assessment and Control Evaluation (FACE) program.

We are sensitive to the need to translate technical findings into terms that are meaningful for non-technical audiences. A recent example is an educational document that we developed to supplement our 1998 criteria document on metalworking fluids. Where the criteria document was a comprehensive scientific review of technical information and health data, several hundred pages long, the companion document digested essential recommendations for reducing exposures to metalworking fluids into an easy-to-read, 38-page format.

I agree that in general health research has received disproportionate emphasis relative to safety research. We are changing that balance, particularly with the integration of the former Bureau of Mines research laboratories into NIOSH. We are already getting positive recognition for our leadership in preventing workplace injuries. For example, in FY 1997, Congress provided NIOSH with $5 million specifically to take the lead in a national initiative to reduce childhood agricultural injuries. In FY 1998, we received $2.5 million specifically to investigate, through the FACE program, all firefighter fatalities suffered in the line of duty.

ASSE: We have seen that there has been some change in senior leadership at NIOSH, not counting you of course. Are there any planned organizational changes for NIOSH? Will the Morgantown facility continue to expand? Who are the key members of the NIOSH Leadership Team?

Rosenstock: One major organizational change that occurred relatively recently was our acquisition of the health and safety research functions of the former U.S. Bureau of Mines. The transfer of those duties to NIOSH resulted in the addition of two new locations in the form of mine research laboratories in Bruceton, Pa., and Spokane, Wash., the addition of research staff from those facilities, and the naming of a NIOSH Associate Director for Mining. This was an exciting development for us, because the highly respected research conducted at these laboratories is a natural fit in the NIOSH mission. We do not anticipate any other significant changes in the foreseeable future, or any further expansion in Morgantown beyond our finalizing the staffing for our state of the art laboratory.

The members of the Leadership Team include myself, NIOSH Deputy Director Bryan Hardin, Chief of Staff Marilyn Fingerhut, the five NIOSH associate directors, and the seven NIOSH division directors.

ASSE: One of the biggest areas of debate is which has more impact - injuries or illnesses. An example is that the estimating of disease due to asbestosis can quickly reach the perceived level of being an epidemic. Injuries have not been estimated this way in the past. You have discussed proactive/new ways of measuring the impact of injuries in this country. What are your views on such issues? With your health standards background do you have any ideas on how we can more effectively gauge the extent of injuries in the United States? Do you think injuries might be unfairly discounted due to the recording mechanisms for injuries as related to health?

Rosenstock: You are quite right that new approaches are needed to better measure the risk and impact of workplace injuries, and we are addressing this need. In a study published last year, "Working Lifetime Risk of Occupational Injury," NIOSH developed estimates to identify the 50 industries and occupations having the greatest risk of fatal job-related injury. Not surprisingly, the result indicate that the working lifetime injury risk of some occupations, such as loggers, fishermen, and structural metal workers, is comparable to worker risks for some occupational diseases, such as lung cancer among uranium miners. These results suggest that investments in preventing fatal workplace injuries should be considered equally with investments in preventing work-related diseases such as cancer.

We have better data than ever before to estimate numbers and rates of work-related deaths. Even though employer-based reporting systems are widely acknowledged to underrepresent the prevalence of both injuries and illnesses, we have developed a number of independent surveillance systems, such as the National Traumatic Occupational Fatality program, that actually provide us with more comprehensive data on injuries than on illnesses. A recent NIOSH-funded study C using multiple data sources C has convincingly demonstrated the high toll of both injuries ($145 billion) and work-related diseases ($25 billion) to the U.S. economy each year.

But further improvements are needed, and here again, NORA provides a powerful vehicle for advancing the quality and utility of data. A NORA team on risk assessment methods, for example, includes a strong focus on traumatic injuries. Additionally, a team on social and economic consequences of illness and injury is working to develop economic models to better characterize the magnitude and scope of costs associated with occupational injuries. We devoted a session at last year's National Occupational Injury Research Symposium, organized under NORA, to injury risk assessment. As a follow-up, we have been working with the "Journal of Human and Ecological Risk Assessment" to assemble a special issue on occupational injury risk assessment for December 1998, including papers by NIOSH and others.

ASSE: Our members are encouraged to see the expansion of safety related research at NIOSH, specifically the expansion taking place under Nancy Stout at the Morgantown facility. ASSE has a history of supporting the efforts of the Safety Research Division. Will there be additional expansion for the Safety Research Division?

Rosenstock: Ideally, we would like to see further growth in our safety research program. We are always sensitive to critical needs and are always determined to find avenues for meeting those needs. Realistically, in the final score, decisions on any allocations in NIOSH are subject to the budgetary limitations that I mentioned previously. I would note again that two areas in which we received additional funding in the past two years C in FY 1997, for research on childhood agricultural injuries and in FY 1998, for research on firefighter line-of-duty fatalities C pertain to activities for which the Safety Research Division has the lead in NIOSH. We were gratified that these actions reflected recognition for the fine scientific work performed by Nancy Stout and her staff, and the welcome support of ASSE and other stakeholders. And we are also seeing work related to injuries elsewhere in NIOSH, particularly in our mining laboratories.

ASSE: Some members have suggested that a key concern for NIOSH is that for a relatively small agency, it is rather spread out, (Atlanta, Cincinnati, Morgan Town, and Washington, DC). Will there ever be a consolidation of these locations, or are there reasons to maintain this separation?

Rosenstock: The dispersal is even wider than that, given the locations in Bruceton, Pa., and Spokane, Wash., that we acquired as a result of the transfer of mine safety research functions to us in 1996, as I mentioned previously. If I could wave a magic wand, it would be wonderful in many ways to have all of NIOSH in one place, but I think it is unlikely that any consolidations would be proposed, given the long-standing investments that have been made in equipment and resources at the individual laboratories. The geographical distances between the locations are actually less of a complication for us now than ever before, given the new communications technologies that have come into use in the past few years.

ASSE: How is NIOSH working with new OSHA Administration, and specifically Charles Jeffress?

Rosenstock: NIOSH and OSHA work together closely at both the staff and leadership levels. Charles Jeffress and I meet monthly to discuss priorities and explore opportunities for cooperation and collaboration. At the staff level, NIOSH researchers and OSHA personnel meet frequently to discuss specific projects of mutual interest. As recent examples, NIOSH has provided rigorous scientific input into OSHA deliberations on metalworking fluids, perchloroethylene in dry cleaning, and silica in abrasive blasting.

ASSE: It is no secret that NIOSH has been under attack during the last four years for the perceived reason that the agency does not impact OSHA standards and that the agency is duplicative of OSHA. What are your thoughts on this issue? Is this really a fair characterization? Do we know how many of NIOSH's recommendations/studies are utilized by OSHA during the rule making process? What level of authority do you have in working to ensure that the findings of your agency are consistent with regulations? Why does there continue to be misunderstanding of NIOSH's mission?

Rosenstock: The misunderstanding exists undoubtedly for a variety of reasons. But I think they are lessening. This new awareness of NIOSH is gratifying in that it means we are recognized more and more as having a crucial role in major public issues as a scientific agency, or that we are reaching new audiences, but it does create a potential for confusion among members of the public and others who have little or no background in occupational health and safety.

Unfortunately, where confusion occurs in the context of the attacks you mentioned, I believe at least part of it arises from deliberate efforts by some to mischaracterize our role. NIOSH's research can have tremendous impact in changing the status quo, and some opponents of change have sought to undercut our effectiveness by fostering misinformation about our purpose, our scientific charge, our basic differences from other agencies, and our contribution to the public good. These efforts to muddy the water are counter-productive to everyone. They divert time and energy from solving the problems of workplace injury, illness, and death that burden every individual in the country in one way or another. We have worked diligently to correct the record, and more importantly, to try to head off confusion before it occurs. We deeply appreciate the assistance we have received in this regard from partners such as the ASSE. Having cemented many new partnerships with diverse stakeholders under NORA, we are encouraged that we have opened further avenues for setting the record straight.

In terms of OSHA standards-setting, our experience is that the agency values NIOSH's research and recommendations. In the 1990s, as the technical issues become more and more complex, this role has grown increasingly essential. At the same time, no one should expect that NIOSH recommendations and OSHA standards will be mirror images. Our roles are fundamentally different. OSHA sets and enforces standards that are based on a host of factors, including technical and economic feasibility. NIOSH's mandate is to discover the causes of work-related injuries and illnesses, and to formulate effective preventive strategies. Indeed, our role goes far beyond our working relationship with OSHA. We routinely work with many diverse stakeholders in industry, labor, and government to conduct research and disseminate information in many ways that have everyday benefits for workers, businesses, and society.

ASSE: The position of ASSE is that safety and health practices based on good science and sound technology contribute to the overall organizational/financial health of an organization. There are examples of government regulatory initiatives giving industries the motivation to change processes and procedures which eventually led to significant benefits. Do you have any thoughts on this issue? Many organizations continue to suggest that safety and health is a detriment to the United States. Has NIOSH ever conducted a study indicating the level of positive impact by safety and health? An example would be cost estimates on PPE, but there is never any mention made as to how much product was designed, manufactured, and sold to comply. Can this number be accurately studied? Such an approach could change some of the cost/benefit analysis we continue to hear about.

Rosenstock: NIOSH to date has done very little along these lines. But we are increasingly trying to consider economic costs of illnesses and injuries and economic benefits of preventing them.

We already have some convincing data about why investment in occupational safety and health is prudent. Broad analyses by others suggest that the benefits of health and safety practices significantly exceed the costs. For example, the most recent benefit-cost analysis of OSHA regulations, quoted in a recent report to Congress by the Office of Management and Budget from a 1996 American Enterprise Institute publication, suggests that OSHA rules had produced over $50 billion in net benefits by 1995.

We believe that estimating the value of specific health and safety investments will be particularly fruitful. For example, NIOSH is funding a variety of studies that will help us understand what works best in health and safety, how much it costs, who pays, who benefits, and how they benefit. In addition, NIOSH is designing an intramural study to evaluate the effectiveness of employers' safety and health programs.

ASSE: We know that you have been committed to NORA (National Occupational Research Agenda). The NORA program is continuing to move forward - what are your long-term and short-term views on NORA?

Rosenstock: In the near term, we and our colleagues look forward to continuing the progress made since 1996 in expanding our partnerships in the 21 NORA priority areas , leveraging new resources, defining research needs in the priority areas, and identifying opportunities for collaboration. Perhaps of particular interest for ASSE, the NORA report on traumatic workplace injuries, issued recently, was the first of many white papers that will define national research goals and needs in the 21 priority areas. In the long term, we look forward to facilitating the creation of other broad-based networks in the NORA model, in which we and others will build on lessons learned from NORA and from wide recognition of the benefits generated by NORA.

ASSE: NORA is probably the biggest safety and health research initiative in history. NIOSH is also working with the National Institutes of Health (NIH), and even received a significant grant from NIH. With this new funding, will NIOSH be able to expand NORA?

Rosenstock: We are particularly proud of this partnership with NIH, in which a $5 million Congressional appropriation for NIOSH, specifically earmarked for NORA, was leveraged with $1 million each from three of the NIH institutes to fund the largest-ever investment in extramural occupational health and safety research. Certainly, we hope that the results of this historic teamwork will further expand NORA by encouraging other research organizations to consider similar partnerships under the NORA umbrella.

ASSE: We know that NORA was reviewed by the new Chemical Safety and Hazard Investigation Board as a potential model for their own future research initiatives. Are you working with this new investigation body, and will there be an opportunity for more research?

Rosenstock: Yes, we are working with the board, and we are delighted that it has identified NORA as a model that it has proposed to emulate and adapt in developing and implementing its own research agenda. We have discussed with them in detail the process we used to develop NORA, the current efforts by NIOSH and its partners to implement the agenda, and the elements that have been critical for NORA's success. We look forward to further interactions with them.

ASSE: You are aware that the Society has pushed for some time that it was necessary to redo the "Human Resource Needs Assessment" We understand that $100,000 has been appropriated to perform the study - how is it progressing?

Rosenstock: We are delighted that the Institute of Medicine will be responsible for an assessment to characterize the U.S. workforce and work environment, and to forecast the demand, need, and supply of qualified occupational safety and health professionals over the next several decades. This assessment will identify gaps in U.S. safety and health training programs that can be filled by either public or private training efforts, and the critical criteria and skills needed to meet those needs.

ASSE has graciously offered to be helpful in accomplishing this study, including providing summary information from member surveys. We have appreciated this support all along, and expect that input from our partners like ASSE will be vital for the study. NIOSH will be contributing as much as $300,000 to this effort, and the Institute of Medicine will be seeking additional funding partners from the public and private sectors.

ASSE: In your opinion what benefits will be created by repeating the Human Resources Needs Assessment, specifically to colleges/universities and the different allied safety and health professions?

Rosenstock: As we all recognize, vast changes are occurring in the U.S. workforce and workplace. These changes create new demands for trained, capable professionals in many areas of expertise. In essence, the findings of the study will help the nation anticipate and meet those needs. Among other benefits, colleges, universities, and professional organizations will find the results key for determining what kinds of education and training will be in demand as we enter the 21st Century, so they can plan their programs accordingly. And the findings will be equally valuable for health and safety professionals in designing and delivering their services.

ASSE: We were proud supporters of the National Occupational Injury Research Symposium (NOIRS). Will such an event be held again?

Rosenstock: Yes. We are planning a second symposium, tentatively scheduled for Oct. 17-19, 2000, at a location to be determined. An initial notice will be sent out shortly. Clearly, ASSE's support contributed to the success of the first NOIRS, and we look forward to further success with the second. The fact that we had enthusiastic co-sponsorship from ASSE and 10 other partners for the first symposium, and an attendance of more than 300 professionals from across the U.S. and around the world, is further evidence that the significance of occupational injury is being recognized.

ASSE: What do you see in the future for NIOSH and yourself? Do you have any thoughts you would like to pass on to the ASSE membership?

Rosenstock: First and foremost, NORA will continue to be a model for national teamwork by NIOSH and others to anticipate new challenges, leverage resources, and combine expertise. To appreciate the overwhelming importance of that model, just consider the magnitude of the job currently before us, and multiply that by the profound changes in the workplace and the workforce that lie ahead in the next decade and beyond. Looking at the future of safety research in particular, the recent report by the NORA traumatic injury research team provides a blueprint for next steps. In specifics, we must continue to document success stories in injury prevention, and we must be creative in developing and applying new technologies to workplace safety. I believe this is a very positive era for occupational safety and health C despite the unfortunate contentiousness on some issues. We should, I think, all be proud of our mission and our contributions.

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