"This document was published prior to the publication of OSHA's final
rule on Ergonomics Program (29 CFR 1910.900, November 14, 2000), and
therefore does not necessarily address or reflect the provisions set forth
in the final standard."
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Why is OSHA pushing so hard to complete its ergonomics standard this
year? I want you to know that I've answered that question dozens of
times since last November.
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Of course, all of us gathered here today know the answer.
Work-related musculoskeletal disorders or MSDs are a serious, pervasive
problem throughout American workplaces.
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Every year 1.8 million U.S. workers experience work-related MSDs-back
injuries, carpal tunnel syndrome, or tendinitis, for example. This
includes nearly 600,000 injuries serious enough to cause workers to miss
work-a full third of the most serious on-the-job injuries.
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Here's another way to look at these numbers. Today, this day, more
than 1,500 working Americans will suffer painful injuries related to
overexertion or repetitive motion. These injuries are potentially
disabling and can require long recovery periods. For example, workers
need an average of 28 days to recuperate from carpal tunnel
syndrome-more time than necessary for amputations or fractures.
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MSDs are also very costly injuries. Direct costs of MSDs total $15 to
$20 billion per year. Indirect costs increase that total to $45 to $54
billion. That's an average of $135 million per day.
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But real solutions exist that can spare workers pain and pare
expenses for their employers. It's time we began putting those solutions
to work for everyone's benefit. No worker should take a job to earn a
living only to return home disabled. And no employer should have to bear
the expense associated with injuries that can be prevented.
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OSHA has found substantial evidence that ergonomics programs can cut
workers' compensation costs, increase productivity and decrease employee
turnover. In fact, as you know, ergonomics began as an effort to
streamline work processes and improve efficiency to save money.
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In short, good ergonomics is good economics. It's about working
smarter and safer. That's good business.
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We know better than to push equipment beyond its rated capacity.
That's a surefire recipe for malfunction or breakdown. So why would we
want to push our people beyond their physical capacity? Obviously, we
don't.
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OSHA has spent 10 years studying ergonomics, and the record includes
more than 14,000 studies. During this rulemaking, we have received more
than 8,000 public comments and heard from more than 700 witnesses during
our nine-week hearing.
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The evidence is more than sufficient. It is overwhelming.
Musculoskeletal disorders are related to work, and reducing
repetition, excessive force, awkward postures and heavy lifting
can reduce the risk of injury. The time to act is now.
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In 1995, OSHA developed a draft ergonomics rule that it circulated
for feedback. That draft would have required employers to examine all
jobs against a set of risk factors. High-risk jobs would then need to be
fixed.
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The business community reacted swiftly and strongly. Business
opposition led Congress to pass appropriations riders for fiscal years
1995, 96 and 98, prohibiting OSHA from even publishing an ergonomics
proposal.
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Business was up in arms at the prospect of having to examine every
job in every workplace to determine if doing that job might result in an
MSD. Trade associations and other business leaders wanted OSHA to find a
better way to focus the standard, to zero in on high-risk jobs.
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So we developed a new proposal in 1999 to address this concern. It
asks employers with high-risk jobs-about 25 percent of general industry
employers-to provide information to workers and set up an injury
reporting system. Employers would only need to take action to analyze
jobs when someone actually suffers an MSD.
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Of course, using an injury trigger is not the most preventive
approach. But it zeroes in very effectively on jobs and activities where
real problems clearly exist.
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OSHA's proposal also recognizes that no ergonomics program will
prevent every MSD, and that different people may be affected by
different risk levels. But the injury trigger flags jobs that need
correction to prevent future problems. Witnesses in our hearings also
pointed to the need to identify specific physical risks that led to the
injury and that must be reduced to avoid additional injuries. We were
encouraged to set thresholds for these risks would make it clearer to
employers when a job needs fixing and when they had done enough.
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The state of Washington has used a risk factor approach in its new
ergonomics standard to help employers quickly determine which jobs
require further analysis and possible action. Under WISHA's standard,
employers would need to examine jobs that involve specific awkward
postures, repetitive lifting of various weights or engaging in other
high risk activities for specified periods of time. The Washington state
standard requires worker education and reduction of physical risks in
individual jobs to reduce injuries.
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WISHA expects a 40-percent reduction in work-related MSDs through its
new standard. This is based on research indicating that the lower the
intensity, duration and frequency of exposure to physical risk factors
at work, the lower the risk a worker will develop an MSD. Therefore,
reducing the weight of objects workers must lift, limiting the time
workers must work in awkward postures or cutting the number of
repetitive motions workers must perform should reduce injuries. Evidence
presented in comments to us and at the OSHA hearing indicated this is a
promising approach.
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One of OSHA's commitments in its 1999 proposal was to provide
flexibility for employers in determining how to solve problems. One size
does not fit all. We know it's critical in the final standard to
maintain flexibility and continue a performance-oriented approach.
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At the same time, our proposal was criticized for being vague about
when an employer was in compliance. Employers want to know when they've
done enough. They want to be sure that their response is sufficient to
protect their employees. They want to be certain that their ergonomics
program will meet the approval of an OSHA inspector.
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Finding the balance between performance and specification is very
tough to do. If we're not specific enough, we're not providing the
guidance that some employers, particularly small businesses, may need.
If we're too specific, our requirements won't give employers the
flexibility they need to resolve the unique problems they face. It's
damned if you do, and damned if you don't. But if we must tilt one way
or the other, I think it's most important to maintain flexibility. And
no doubt I'll hear more on this subject from speakers who follow me.
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Now I want to address Work Restriction Protection. This has proven to
be one of the more controversial provisions in OSHA's proposed
ergonomics standard. It has generated a significant amount of public
comment and crossfire during the hearing-even though earlier OSHA
standards have required similar medical removal protection. And in the
case of high blood lead levels, workers may be removed from jobs
involving lead exposure for up to 18 months. We proposed a six-month
limit for WRP.
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Under WRP, employees would receive full pay and benefits for light
duty work and 90 percent of net pay and benefits if they have to miss
work. And WRP payments are offset by any workers' compensation that
injured workers receive.
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The key to preventing serious disability as a result of MSDs lies in
early reporting. And more than any other OSHA standard, the ergonomics
proposal depends upon individual workers coming forward promptly to
report their injuries.
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OSHA's experience has shown that workers may be reluctant to report
problems early if doing so will cause them to miss work and lose pay. We
must find a way to reassure employees that they won't be penalized for
reporting injuries. This is particularly a problem for workers at
smaller businesses, which often do not provide sick time. Currently, if
their employer directs them to take a few days off to recover from
tendinitis, workers who do so know their next paycheck will be short.
So, a worker may decide instead to put up with the pain in hopes that it
will just go away.
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In our final standard, we need to include some strategy that
encourages early reporting to reduce both the incidence and severity of
MSDs. When we depend so heavily on workers to report problems, we must
find a way to encourage them to do it sooner rather than later, before
irreversible damage occurs.
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And we are close to a final standard. I expect that our final
standard will be published by the end of the year. After that, our
challenge will be to provide employers with the assistance they need to
implement programs that fit their workplaces.
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What we must remember is that real solutions are available to fix
problem jobs. And when we identify them, both employers and employees
will benefit.
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While ergonomics relies on a scientific approach to fit the job to
the worker, it isn't necessarily exact. Sometimes it requires
experimentation. But every safety and health professional can identify
solutions that eliminate musculoskeletal disorders that result from a
mismatch between the job and the worker.
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Solutions can be simple, obvious and inexpensive. Things like adding
a platform to reduce reach, padding hand tools and work surfaces,
substituting a more effective tool or reducing the size of items workers
must lift. These are sensible approaches that reduce risk without
reinventing the factory. Often they are suggested and developed by the
workers in the jobs that need to be fixed.
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While we have sound science linking work and MSDs, there is clearly
room for more research. The research work that panelists here are doing
is important. You've focused on an issue that is in the forefront of
safety and health. And your research has the potential to significantly
improve lives.
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How can we design the work environment and the work flow to minimize
physical stress? How can we re-design common jobs that have already
resulted in injury? How can we address ergonomics in other industries
like construction? What solutions are in use in Europe or Japan?
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Are there more objective measures of MSDs that we could rely on? What
strategies prove most effective in treating various MSDs? What new
interventions might be successful?
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We need your contributions, and we welcome them. We want to send
every worker home whole and healthy every day. Your work will guide
employers and employees in finding practical solutions to common
problems to prevent injuries. We appreciate your partnership in creating
safer workplaces, and we look forward to working together in the
future.