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"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."

• Who can predict the future with absolute certainty? No one really. There are too many variables, too many unknowns. But that doesn't stop prophets and futurists in every age from trying.

• And it doesn't stop each of us from making the best decisions we can based on the information we have available. We are all forced to face the future standing in the present with only the past to guide us.

• That brings us to the topic for today-work-related musculoskeletal disorders. WMSDs are linked to all three time frames. Ergonomics is an issue with a long history that demands our attention today lest we sacrifice our future health tomorrow.

• I believe the issues are simple.

  • Do musculoskeletal disorders represent a serious problem for our workforce?

  • Is there solid evidence tying these disorders to work activities?

  • Do we know how to solve ergonomic problems when we find them?

  • Is now the time to act on this issue?

• The answer to all of these questions is YES. OSHA has been concerned about work-related musculoskeletal disorders for more than two decades. With good reason.

• On-the-job injuries continued to decline in 1997. But overexertion, repetition or other physical stress continue to be a major factor in serious injuries and illnesses. And they consistently account for one-third of all injuries.

• We are not talking about sore wrists or stiff muscles here. We are talking about conditions so serious that they require time away from work. Real people, real injuries. These numbers are not based merely on complaints filed by workers, but the assessments of employers who identified these injuries and reported them to BLS.

• WMSDs cost business $15 to $20 billion each year in workers' compensation costs alone. And business wouldn't be paying these bucks if the problems weren't job-related!

• The notion that we have no "sound science" linking work to MSDs or demonstrating that ergonomics programs prevent these injuries is a spurious argument. It makes good newspaper copy. But the evidence belies the charge. In fact, there are real solutions.

• There are extensive, excellent studies that address work-relatedness of MSDs and the effectiveness of ergonomics programs. In 1997, the National Institute for Occupational Safety and Health looked at 2,000 studies spanning several decades and evaluated 600 in depth. At least 27 scientists peer reviewed the NIOSH findings. GAO also examined five specific ergonomics programs in a case study review in 1997.

• In 1998, the National Academy of Sciences conducted its first study. That review of the literature verified that substantial sound scientific evidence links back injuries, carpal tunnel syndrome and other MSDs to work. The Academy concluded that workers who face high physical stress-such as heavy lifting and repetitive motion-have high rates of MSDs. Further, the Academy pointed out that most people face their main exposure to such physical stress on their jobs. But even more importantly, the Academy noted "compelling evidence" that reducing biomechanical stress on the job reduces the risk of injuries. This literature survey also was submitted for peer review.

• These studies pretty well answer the major questions about the work-relatedness of musculoskeletal disorders and the usefulness of ergonomic programs. So I have some questions for the Coalition.

• What different conclusions do you expect from yet another literature review by the Academy? What will you say if the findings are identical to the last review? Can I then expect your enthusiastic and vocal support for ergonomics programs? Will you give this to me in writing?

• The truth is plain and simple. More research is always welcome, but we already know enough to begin addressing these problems. We don't know everything about cancer, but we do everything we can to prevent and treat it.

• Many of the corporations that you or your association represent are taking steps to prevent work-related musculoskeletal disorders. This is truly a case where actions speak louder than words. Your words bewail the lack of science. Your corporations' actions tell a different story. The actions indicate your employers believe that spending money to improve ergonomics can benefit both the workforce and the company's bottom line.

• Your campaign against an OSHA standard denounces ergonomics programs as costly and of questionable value in preventing injuries. Yet many of your corporations have established programs that qualify for grandfathering under the OSHA draft proposal! There's a serious disconnect here. If ergonomics programs are a drag on productivity and a drain on profits, why are you establishing them? Because the opposite is true: good ergonomics is good economics.

• Individually many of the 200 companies that publicly support the coalition's effort to discredit and delay an ergonomics standard have also established ergonomics programs. I challenge those corporations to preach what they practice. I urge you, as spokesmen and spokeswomen for these corporations to understand that people see you as saying one thing and doing another. You cry "wolf" about ergonomics, while at the same time investing in ergonomics programs to protect your employees. Have you no shame? Do you not care about the reputation for misrepresentation that you are creating for your corporations?

• The reason your companies have established ergonomics programs is that they work. We know they work because employers have told us so. We have practical information from more than 300 companies verifying that the programs they have established have prevented injuries and cut costs. So, the actual experience of business is at variance with vague claims about outlandish costs and questionable benefits.

• Let me tell you just one story. The company is Sysco Food Services of Houston -- a food services distributor. We inspected Sysco in 1996 and issued a $7,500 penalty for posture and lifting hazards. In 1996, the company had 201 injuries with 3,638 lost workdays. Back injuries accounted for almost 40 percent of the injuries and more than half the total cost.

• Under the direction of a new occupational health nurse, Sysco formalized the ergonomics program it had recently begun at the time of our inspection. Just one year later injuries and illnesses had dropped 25 percent, and the cost of cases was down by more than 45 percent. For the first eight months of the company's fiscal year 1999, total costs are down to about a quarter of the 1996 total. Major back injuries have dropped from 76 to 21.

• How did they do it? One step at a time. Sysco instituted an early return to work. The company set up ergonomics committees for both shifts. The nurse surveyed workers, trained workers and supervisors, analyzed jobs for hazards and set up a medical management program with the company's health care providers. Workers are encouraged to report symptoms early -- whether they're work-related or not -- to nip problems in the bud.

• Sysco also invested in other changes. The company re-racked its warehouse. It put brakes on handtrucks. It issued new shoes with better traction to all warehouse and delivery staff.

• In addition, Sysco assessed its customers -- old and new -- for ergonomic hazards during delivery and worked to improve the situation. The company even dropped one prestigious account -- only to regain it later when the customer was ready to work cooperatively to make things safer for Sysco employees. The company also requested -- and got -- changes in packaging from suppliers -- smaller bags, handles on packages, sturdier cardboard and lighter boxes.

• Ergonomic programs work. They reduce injuries. They improve employee morale. And they save money for employers.

• The benefits are clear. I would not be guiding OSHA forward on this issue if I did not believe that. Workers are being hurt. This is costing business money. Companies that take action are preventing injuries and saving money. Ergonomics is clearly a win/win proposition.

• So, the real issue is the details. I challenge you to work with us to get this rule right. I want to strongly encourage you to participate in the comment period and hearings. Tell us about your experience with ergonomics. Work with us to write the best possible standard that will help your business and others address the muskuloskeletal injuries that are affecting them.

• We need to encourage all employers to follow the best practices that the leaders throughout industry have already adopted. It's time we moved ergonomics beyond the best companies to the rest of the companies. It's time every worker could look forward to heading to work without facing pain or fearing disability.

• Others with expertise in occupational health and work-related musculoskeletal disorders have also indicated that it's time to move forward in addressing ergonomics:
  • the American College of Occupational and Environmental Medicine,
    
  • the American Academy of Orthopaedic Surgeons,
    
  • the American Association of Occupational Health Nurses,
    
  • the American Industrial Hygiene Association,
    
  • the National Advisory Committee on Occupational Safety and Health,
    
  • the American Public Health Association,
    
  • the AFL-CIO, and
    
  • numerous individual unions and individual employers.
    

• In other words, there are real solutions to make a real difference in the lives of real people. The keys to success are simple: reduce repeated motions, forceful hand exertions, prolonged bending or working above shoulder height. Eliminate vibration. Rely on equipment-not backs-for heavy or repetitive lifting. Provide "micro" breaks to allow muscles to recover.

• No, ergonomics is not an exact science. That's because we're dealing with individuals, not robots. Apply the basic principles and adjust as needed. There's some trial and error involved. But it's not rocket science either.

• Let me just say a word about where we are in the standard-setting process. I'm sure all of you have seen the draft proposal we shared with the small business panel under the Small Business Regulatory Enforcement and Fairness Act. It's on OSHA's website at www.osha.gov.

• I expect to receive the report of the SBREFA panel next week. We'll consider the recommendations of the panel, make changes and then send the draft on to the Office of Management and Budget. We'll publish the formal proposal-complete with preamble-for public comment this fall. Then we'll hold hearings in several cities and expect to issue a final standard by the end of the Year 2000.

• The OSHA draft rule provides a flexible framework that enables employers to address WMSDs in a sensible, practical manner. Employers who've developed effective ergonomics programs tell us that's the approach they use. We've based this draft on existing good industry practices-interventions that businesses are actually using, that have been proven effective in protecting workers. Employers told us they use the ergonomic guidelines we published for the red meat industry in 1990. We've drawn heavily on those guidelines in developing this proposal.

• One size does not fit all. That is why OSHA has decided on the program approach. That's also why no one will ever be able to say that X number of repetitions or lifting X pounds will result in injury or conversely that Y number of repetitions or Y pounds will definitely NOT result in injury for anyone, any time, anywhere. However, many employers have proven that establishing a systematic program to address such issues as repetition, excessive force, awkward postures and heavy lifting, results in fewer injuries to workers.

• I think that a program approach offers employers the framework for addressing specific high risk areas and then handling other problems as they arise. It's the right way to go to provide needed protection for workers while providing maximum flexibility for employers.

• It's important to note that OSHA is not acting alone. As you know, the State of California last year put an ergonomics standard in place. And Washington State and North Carolina are now working on standards of their own. While we applaud their individual efforts, we also are concerned that the nation not end up with a patchwork of ergonomic requirements that could have serious consequences for interstate businesses and their workers.

• Not long ago, one of OSHA's critics pointed out that 80 percent of Americans suffer back pain at some point during their lives. He suggested that was reason enough not to worry. For him, back pain represents the norm -- something to be expected. Take two aspirin and hope it goes away.

• In fact, I believe the opposite is true. A twinge or two is one thing. But a serious, disabling injury cannot be dismissed as something everyone experiences. Real people are experiencing real injuries -- and there are real costs involved.

• Work-related musculoskeletal disorders are a national problem that we must address. And we need not, should not and cannot wait any longer to do so.