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• Fact Sheet
• What Doctors Say About Ergonomics
• Repetitive Stress Injuries (RSIs) Not an Epidemic
• RSI Pie Chart
• OSHA's Ergonomic Myths vs. The Facts
• Questions and Answers About OSHA Ergonomic Regulations

Should Businesses Become Laboratories For Costly, Unscientific Government Regulations?

That's exactly the result under the ergonomic regulation just promulgated by the Occupational Safety and Health Administration (OSHA). This regulation forces experimental, unproven and financially ruinous requirements on virtually every private employer in the nation (with the exception of specified industries that are not yet covered). It forces employers to teach employees the scientifically invalid and false assumptions underlying the rule as if they were truths. Yet, despite the billions of dollars it will cost, this ergonomic regulation will not assure the prevention of a single injury.

Ergonomic Principles Make Sense

American businesses continue to apply ergonomic principles in voluntary applications. Ergonomics as a non-mandatory common-sense approach is currently utilized by employers across the country to help make the workplace more comfortable and more productive.   Ergonomics never was and is not now a tool for reducing injury.

A Costly Mandatory Ergonomic Regulation That Fails to Provide Injury or Illness Reduction . . . Makes NO Sense!

This one-size-fits-all regulation that treats jobs in every company across industries the same makes no sense. The bureaucratic approach mandated for virtually every place of employment, bakery, factory, delivery truck and office in the nation is so unworkable it would be laughable were it not for the serious consequences that will result from this rule.

Small businesses will be hit the hardest by this regulation because most of them just can neither afford to invest in expensive new experimental equipment, nor afford the tremendous burden of deciphering a time-consuming, complex and confusing regulation. Many small businesses would simply have to close their doors or face the wrath of government inspectors and enforcers.

Imposing an Experimental "Solution" for a Problem on Which Science Materially Disagrees

The inherent problems in developing any regulation on ergonomic practices in the workplace stems from a complete lack of consensus as to the causes and remedies for musculoskeletal aches and pains. Two beauticians perform the same task every day. One develops a back strain, the other does not. One factory worker suffers neck pains, the other does not. A waiter experiences a sore wrist, but his co-worker is fine. A vast array of medical and scientific studies demonstrate that the causes of musculoskeletal complaints are multiple and varied and, based on valid prospective studies, are not causally associated with one's physical activity as presumed by this rule.  Rather, one's likelihood of suffering these aches and pains of daily living is much more associated with the individual's general health, genetics, personal general conditioning and physical fitness, vitamin in-take, and, most importantly, the individual's perception of his or her job satisfaction level and the level of general stress in the individual's life.

Reported Injuries are on the Decline

While musculoskeletal injuries are a concern, the fact is they are not a rising concern. Over the past four years, such injuries have declined by 24%, representing 4% of the total injury and illness picture.

A High Price to Pay for No Assurance of Prevention

Who gets hit the hardest by this far-reaching and costly regulation? Those who can least afford it -- small businesses that would be forced to comply with the regulation, and consumers who will pay higher prices for goods and services. When businesses are forced to spend billions complying with government regulations, many would be forced to close shop, contract with foreign suppliers, or automate jobs, all of which would result in laying off employees. We must create jobs, not eliminate them.

This regulation will make American industry non-competitive with the world market. It will drive manufacturers to automate and eliminate jobs at an accelerated pace. Under this rule, employers cannot expect workers to expend any material physical effort as such.   Every business that can will substitute machines for people.

No Promise of a Single Prevented Injury or Illness

Employers don't question whether they should spend billions of dollars to prevent workplace injuries and illnesses. They already do.  More precisely, the question is: Should employers be forced to spend billions of dollars to make experimental changes that have never been shown to prevent a single illness or injury and in some cases, because of their experimental nature, will increase injury and susceptibility to injury?

Ergonomic Principles When Voluntarily Applied as a Productivity Enhancement Tool Make Sense.

Costly and Ineffective Mandatory Regulation in this Area Makes NO Sense.

WHAT DOCTORS SAY ABOUT ERGONOMICS

While promoters of ergonomic regulations continue to claim adequate information exists to regulate workplaces for ergonomics, leading medical experts disagree. Here is what they have to say.

The causes of "ergonomic injuries"

“With ergonomics, there is no consensus on how to accurately identify a hazardous exposure.”

Dr. J. Steven Moore
Co-director, Ergonomic Center
Texas A&M University
Safety + Health Magazine, November 1998

“[T]here are no conclusive studies showing objective findings that there is a causal relationship between specific work activities and the development of complaints termed RSI (repetitive stress injuries).”

Dr. Blair Filler
Clinical Professor, Orthopaedic Surgery,
University of Southern California Medical School
Testimony before Cal-OSHA, January 1996

“There is no compelling data that ergonomic interventions (either task modification or education regarding biomechanics) aimed at physical demands abrogate disabling back or arm pain. To the contrary. Most studies are disappointing at best.”

Dr. Nortin M. Hadler
Professor of Medicine, University of North Carolina
Letter to North Carolina Department of Labor, August, 1998

“Most occupations have little or nothing to do with causing carpal tunnel syndrome.”

Dr. Robert Szabo, Chief
Hand and Microvascular Surgery, University of California, Davis
Washington Post, March 12, 1996

“The debate concerning whether certain occupations actually cause repetitive motion disorders is now well over a century old and far from settled.”

Drs. Steven Atcheson, John Ward, and Wing Lowe
American Medical Association's
Archives of Internal Medicine, July 1998

“There is no conclusive evidence as to whether alternative keyboards can reduce the risk of musculoskeletal disorders such as carpal tunnel syndrome.”

Dr. Linda Rosenstock
Director, National Institute for Occupational Safety and Health
CTDNews Bulletin, January 1998

"[W]e see no scientific evidence that they are singularly work-caused. That would help explain why two employees, working side by side, performing the same work present different outcomes.”

Dr. William McMaster, President
California Orthopaedic Association
Los Angeles Times, June 16, 1996

"This study confirmed our hypothesis that patients diagnosed as having work-related CTS [carpal tunnel syndrome] have a high prevalence of concurrent medical conditions capable of causing CTS without respect to any particular occupation."

Drs. Steven Atcheson, John Ward, and Wing Lowe
American Medical Association's
Archives of Internal Medicine, July 1998

The regulation of ergonomics

“Any attempt to construct an ergonomic standard as a remedy for regional musculoskeletal injuries in the workplace is not just premature, it is likely to be counterproductive in its application and enforcement.”

Dr. Nortin M. Hadler
Professor of Medicine
University of North Carolina
Testimony before Congress, May 1997

“There is inadequate information at this time to promulgate a specific standard.”

Dr. J. Steven Moore
Co-director, Ergonomic Center
Texas A&M University
Safety + Health Magazine, November 1998

“It is our conviction that there is no scientific basis at this time which would warrant broad regulations and/or legislation on ‘repetitive stress injuries.”

Dr. William McMaster
California Orthopaedic Association
Los Angeles Times, June 19, 1996

“We are not at that stage where we can promulgate certain suggestions in terms of what we should do to treat patients with repetitive motion disorders.”

Dr. Stephen Katz, Director
National Institute for Arthritis,
Musculoskeletal and Skin Diseases
Testimony to Congress, June 1996

“While there have been some recent heated exchanges in the press about the literature's support for an ergonomic mandate, we were unable to find scientific support of any useful intervention other than conditioning [that is, more physical activity, not less as mandated by OSHA's rule] back muscles for nurses who must lift patients.”  (emphasis and explanation added).

Dr. Stanley Bigos
Professor of Medicine, University of Washington
Study released, June 1996

“There are inconsistencies between OSHA's claims regarding study findings and what the cited research actually shows. In addition, OSHA's findings did not fully consider non-occupational factors.... Without question, as a foundation for ergonomic regulations, OSHA's analysis of medical research is scientifically flawed.”

Drs. Howard Sandler and Richard Blume
Sandler Occupational Medicine Associations
Report released, January 1996

Repetitive stress injuries (RSIs), sometimes referred to as ergonomic disorders, do exist. But is there an epidemic of RSIs, as some people say? No, say the actual numbers.

Repetitive stress injuries make up 4% of total workplace injuries and illnesses. 4%! And RSIs account for less than 1% of injuries and illnesses that keep workers off the job.

Does that mean we shouldn't be concerned about RSIs? No. But it certainly doesn't mean we have an epidemic, not by any stretch of the imagination. Now if that doesn't square with the numbers you may have seen - it's because some commonly used numbers about RSIs do stretch the imagination, quite a bit.

For example, the Occupational Safety and Health Administration, OSHA, has said that RSIs account for 60% of new workplace illnesses. But to get that number, OSHA counted in conditions like hearing loss, which often are age-related. OSHA included all back injury claims, even though many of those injuries had nothing to do with RSIs. And OSHA did a little picking and choosing about what injuries and illnesses it figured in, to make the RSI numbers come out at epidemic proportions.

Why would OSHA do that? To justify moving forward with new ergonomic regulation, and it is moving forward with a regulation - even though medical experts say we still don't understand what causes repetitive stress injuries, what would prevent them or how to cure them. We still don't understand why one worker might develop an RSI, and another doing exactly the same work, doesn't. Which is to say, we can't write an effective regulation yet.

But rather than wait for a medical diagnosis, OSHA is rushing ahead with a political cure - a new federal regulation. And while we don't know what the medical benefits might be, and in fact, given what we know, there's no guarantee of ANY medical benefits - we do know the costs would be staggering - billions of dollars to businesses around the country.

To end an epidemic, drastic measures might be in order.

But look at the numbers for yourself, RSIs are not a big part of the injury and illness picture on the job.

MYTH: "Ergonomic disorders represent the country's number one workplace health problem."

FACT: Repetitive stress injuries represent 4% of the total workplace illness and injury picture, according to the U.S. Bureau of Labor Statistics. The numbers for these injuries have been trending downward significantly in the past four years -- a 24% decline.

MYTH: "There is an adequate scientific basis for OSHA to go forward with an ergonomic standard." It is often stated in terms like, "there is an adequate scientific basis to establish that many musculoskeletal injuries are work-related."

FACT: There is a complete lack of consensus in the scientific and medical communities as to the causes and proven remedies for "repetitive stress injuries" (RSIs). Moreover, relationships between work tasks and repetitive stress injuries claimed are never quantified in any way to predict how many might be suffering as a result of work activity. The scientific literature is awash with studies that fail to provide scientific evidence, instead relying on anecdotes and testimonials for "proof." In addition, there is an entire body of literature citing non-work factors as increasing one's likelihood of contracting an RSI, such as weight, diet, vitamin deficiencies, pregnancy and stress at home.

MYTH: "A new, independent study is simply a delay tactic by the employer community."

FACT: The debate has gone on for more than five years and shows no signs of abating. Proponents of a federal standard continue to assert without foundation that enough is known to act now. As noted by the American Society for Surgery of the Hand and the American Academy of Orthopaedic Surgeons, scientific consensus on these matters continues to elude us. Because a consensus does not exist, a comprehensive review of the information base has been directed by Congress, to be completed by the National Academy of Sciences, to identify gaps in knowledge, to establish a common language, and to propose an adequate research agenda to fill those gaps. The employer community is willing to live with the results of this independent, unbiased, comprehensive study. OSHA should not be able to promulgate a standard based on anything less.

MYTH: "The U.S. is one of the few countries in the world lacking an ergonomics standard."

FACT: Nearly all of the standards cited on OSHA's own "List of Comparative Ergonomic Standards in Other Countries" are not ergonomic standards at all. The listed standards fall into several neat categories: manual handling, video display units, vibration, lighting, etc. For some, there are already OSHA standards, for example, material handling. For others, the so-called "standards" are guidelines, not mandatory, legally enforceable standards. OSHA cites (incorrectly) an unfinished ANSI standard for the National Safety Council's Z-365 Committee, on which there is a total lack of consensus within the drafting committee itself.

MYTH: "Ergonomic programs in individual companies are working; thus an ergonomic standard will work."

FACT: There is a huge and unbridgeable gap between anecdotal evidence and a sound scientific foundation. Individual companies are well positioned to study and determine what works for their employees. However, anecdotal examples do not support imposition of a regulation across an entire economy. Absent sound scientific evidence, OSHA cannot extrapolate from these isolated examples to a national rule. Any government-imposed standard would be a one-size-fits-all regulation because it would not be written for any one individual company's workers and work sites.

MYTH: "OSHA has a responsibility to promulgate a standard in this area."

FACT: An ergonomic standard would be irresponsible from a scientific and medical perspective. There is simply not enough scientific evidence for OSHA to issue a legally enforceable standard under its statutory mandate.

The American Society for Surgery of the Hand (May 1996) concluded that there is no consensus, that the language of ergonomics in itself contributes to misunderstanding rather than clarity, and that dangerous and crippling treatments have been advocated so that the affected individuals become victims of the very treatment that is supposed to cure. This is not acceptable.

MYTH: "The NIOSH review settled the argument on sufficient science."

FACT: Nothing could be further from the truth. While the executive summary of the NIOSH review attempts to leave the impression that the issue is settled, in reality, the study found sufficient evidence for relationships between work and injury only in the most general terms and only for a limited number of cases.

Accordingly, the NIOSH report does not even come close to satisfying the need for an independent, scientifically sound, weight-of-the-evidence review.

MYTH: "Employers should support an ergonomic standard because it would save them money."

FACT: If there were any real evidence this were true, the employer community WOULD support an ergonomic standard. This is the very crux of the problem. There is simply no assurance an ergonomic regulation across industries and workplaces will prevent a single injury. Some companies are spending money on ergonomic consultants and new equipment and seeing workers comp costs decline, others are seeing their costs increase; still others are seeing no change whatsoever. In addition, OSHA has no idea what its standard would cost American employers. The agency's last draft was estimated to cost the trucking industry $6.5 billion by one economic analysis.

At the very least, these elements would be enormously time consuming for those who already abide by more than 4,000 OSHA rules and regulations.

Q: Who is the National Coalition on Ergonomics?
A: A growing coalition of organizations and employers opposed to OSHA's experimental ergonomic regulation.

Q: What is ergonomics?
A:  Ergonomics is a descriptive term that is properly applied to an industrial engineering approach to workplace design that is intended to derive maximum productivity from the workplace by assuring that worker discomfort and fatigue are minimized. Ergonomics is not a tool for achieving safety design.

Q: Sounds good. Why is the National Coalition on Ergonomics opposed to an ergonomic regulation?
A: Ergonomics is a good thing in the voluntary setting in which the business decides if a particular design concept is cost/benefit justified.  It's impossible to develop an appropriate mandatory regulation on ergonomic practices in workplaces as a purported safety standard when there is a complete lack of consensus as to the causes and remedies for back, arm, neck and other musculoskeletal aches and pains, which OSHA now defines as musculoskeletal disorders.

Q: Don't employers want to do something?
A: It is in the best interest of employers and workers to reduce on-the-job injuries. Employers have already spent millions of dollars to implement programs that are reducing reported injuries. However, to impose a costly, far-reaching government regulation to address symptom complaints when no one knows if it will actually reduce injuries and make workplaces safer is ridiculous!

Q: What is OSHA mandating?
A: OSHA has promulgated a regulatory program that effectively gives it the authority to order business to implement expensive, experimental measures, including: reconfiguring workstations and even buildings, changing break schedules for employees, automating job tasks and even requiring the hiring of additional staff.

Q: Who would be affected by this rule?
A: All general industry work places, including small businesses, accounting for an estimated 102 million workers.  The standard does not apply to construction, maritime, agricultural and railroad operations.  The rule says these businesses must comply if they have one symptom complaint, which OSHA now defines as an MSD incident.

Q: If employee injuries are reduced, won't that save businesses money in workers compensation costs and lost time?
A: Yes. And if experts agreed on a regulation that would reduce injuries and save money, business would support it. But the current ergonomic regulation can't guarantee a single injury or illness would be prevented.  In the meantime, billions of dollars would be spent on experimental hypothesis based on uncertain suppositions.

Q: But shouldn't we still be taking steps to reduce the existence of MSDs?
A: Absolutely.  It's in the best interest of employers and employees to create improvements in their work areas.  And businesses all over the country are doing just that.  They are initiating voluntary programs, flexibly adjusting to new research or specific findings they discover.  However the science that is reputable in this area tells us that it is activity-tolerance conditioning, not less activity, that is the proper solution.  Programs that address the psychosocial factors that contribute to employees' expression of musculoskeletal pain must be pursued.

OSHA's misguided focus and assumption that biomechanical factors (such as weight, force and repetition) at work cause MSDs is both a false trail and one which will be followed only at great expense and with no benefit to workers.

OSHA has given America a prescription for a weak workforce that is increasingly incapable of performing the slightest physical task.

Q: Both sides of this debate cite their “experts” and their “studies.”  How do I know whom to believe?
A: A multitude of medical and scientific studies have shown that RSIs have a variety of causes.  For example, two people have the same tasks and only one suffers a back strain.  Why?  The MSD causes are many and varied: inadequate physical conditioning of the worker, genetic predisposition, underlying disease, improper use of equipment, stress factors at home, vitamin deficiencies and job dissatisfaction.   With no clear cause and effect relationship, this is a situation that cries out for more research, not OSHA's regulation.

Q: Are there currently any regulations in place to protect employees from injury and illness in the workplace?
A: Yes. By law, every employer is under an obligation to provide a safe workplace for all employees. There are a number of regulations currently enforced by OSHA that are designed to protect the health and safety of workers.