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Dr. Carter J. Kerk, Chair of the National Advisory Committee on Ergonomics (NACE), opened the sixth and final meeting at 10:00 a.m. on Wednesday, November 17, 2004. Approximately 20 members of the public were present during the course of the meeting. The following NACE members were present:
Chair Kerk welcomed members of the public and called the roll for the Committee members. W. Corey Thompson of the American Postal Workers Union was not present. Chair Kerk reviewed the agenda as well as the NACE charter, noting that this would be the last meeting of the Committee and the charter would end on November 30, 2004.
Before approving the minutes from the May 2004 meeting, he asked for any corrections or changes. Dr. Lida Orta-Anes asked for clarification on whether the Committee has begun communicating with the American Society of Safety Engineers (ASSE) to assess where there might be mutual areas of interest. A conference call was to be set up so that the two groups could start collaborations.
Chair Kerk noted that he had previously talked with representatives of ASSE, and that the Outreach and Assistance Working Group would address the item during their report later in the afternoon. The minutes were then approved.
Chair Kerk also noted that the Committee members had been given a document that summarized each recommendation NACE had made from January 2003-May 2004. The list would be updated at the conclusion of this meeting.
Presentation from the Guidelines Workgroup (Part I)
Mr. Dan McCausland said that the Guidelines Workgroup had drafted additional recommendations for the development of guidelines, outreach and assistance efforts, and research.
Mr. McCausland explained the main points of the Workgroup’s recommendations. The draft read:
Dr. Orta-Anes recommended adding the following sentences to the first point: "Ergonomics is a noun, not an adjective," and "It is recommended that it is used in formal documents as such."
She next recommended that in the first point, ergonomics be defined as a process, not a tool. She also recommended that point two and three be combined and the information regarding the pursuit of a definition of MSDs be eliminated. She asked that the third point be altered to read: "MSDs are a consequence of exposure to risk factors of a multi-factorial nature. The common proper objective of ergonomics is to control these risk factors, hence reducing the physiological cost of doing work. To this end, a number of tools and guidelines may be used."
Mr. McCausland said the Guidelines Workgroup would modify the first point per Dr. Orta-Anes’ suggestion since it was consistent with the intention of the Workgroup. He also agreed to change the word "tool" to "process."
He explained that they had kept the definition issue separate from tools and guidelines because they were each important enough to be their own point.
Dr. Audrey Nelson asked for clarification on whether the Workgroup’s recommendation was to adopt the five points as a whole or to recommend the five points separately.
Mr. Paul Fontana said the list was to be considered for the purpose of guidelines development, and therefore, the points did not need to be treated as individual recommendations. He added that the intent was to have the Committee on record as saying it is not important to focus on the single issue of developing a definition of MSDs.
Dr. Morton Kasdan asked that the group add "general health" to the list of examples in number 5.
Ms. Lisa Brooks commented that the recommendation limited the use of the term ergonomics to only the physical demands of the workplace, when ergonomics is broader than that and can do more than address just MSDs. She asked if the first sentence in number 1—"the human interface with the work system"—involved more than just the physical side of work.
Mr. Fontana suggested adding "psychosocial",among other terms, to the list of examples, to show the expansiveness of MSD causation.
Ms. Brooks said if the examples provided in the list refer to the physical side of work and ergonomics, she would be comfortable with that.
Mr. Fontana said it would be fine to add "behavioral", "cognitive," or other terms there.
Chair Kerk commented that he thought the Committee agreed with the recommendation in general, but wanted to see a few words changed. He suggested that the Workgroup and anyone else interested in commenting on the recommendation meet privately to discuss any further changes and then report back to the full Committee.
Mr. McCausland asked if Ms. Brooks would be satisfied if the word "physical" were removed from the statement.
Ms. Brooks replied that it would be a step in the right direction.
Mr. Koskan said the Guidelines Workgroup had another issue they wanted to present to the entire Committee for feedback. Mr. Koskan referred to the fifth point in the Committee’s Charter: "Ways to increase communication among stakeholders on the issue of ergonomics." He said the Committee had heard testimony about the notion that off-the-job exposures, which significantly impact the risk of MSDs, must be addressed when assessing workplace problems. Given that assumption, he asked if it was within the bounds of the Committee’s charter to recommend that OSHA form partnerships and share information with organizations that deal with disorders occurring outside the workplace.
Ms. Barbara McCabe said it is important to consider the worker in what is effective and what is not. She said that when workers are trained and educated about ergonomics, much of what is learned filters to workers’ actions outside of the workplace.
Mr. Koskan clarified his question, asking whether the Committee has a responsibility to make a recommendation to OSHA to establish some liaisons and partnerships with the public health community.
Chair Kerk asked for further comments and then tabled the discussion of the Guidelines Workgroup’s recommendation.
Presentation from the Research Workgroup
Ms. Roxanne Rivera led the presentation for the Research Workgroup. She thanked OSHA and Tom Waters of NIOSH for their help over the past 2 years. She reviewed the research component of the NACE charter, emphasizing that the group was tasked with identifying gaps in the existing research base related to applying ergonomic principles to the workplace, and also current and projected research needs and efforts.
She indicated that the Workgroup had identified eight research gaps and was recommending that the Committee recommend to OSHA that they work to address those research needs. She explained that, like the other Workgroups, the Workgroup used the term MSDs but chose not to define the term. The Workgroup concluded that:
Mr. Willis Goldsmith explained that by highlighting psychosocial factors in the second point, the Workgroup was trying to emphasize that of all of the multi-factorial causes that are related to MSDs—psychosocial factors, in particular—need more research. He continued that the sixth point addresses the need for research that both isolates individual causes and determines how those individual causes relate to each other.
Dr. Morton Kasdan confirmed that behavior was included in the psychosocial component.
Mr. McCausland commented that many of the gaps were consistent with the Guidelines Workgroup’s presentation. He also asked about the Research Workgroup’s decision to not define MSDs.
Dr. Orta-Anes explained that there was a lengthy discussion about the definition of MSDs, but in the end the Workgroup decided to define them in the context of what they were discussing.
The Committee reached consensus and approved the Research Workgroup’s recommendation to forward the list of research gaps to OSHA.
Presentation from the Guidelines Workgroup (Part II)
Mr. McCausland reviewed the Workgroup’s changes. He noted that they had not changed the opening statement. He then read the revised first point to the Committee, noting several changes to the wording. The revised first point read:
"Ergonomics is a noun, not an adjective, and it is recommended that it is used as such in formal documents as it exists in the form of poorly designed work practices and/or workplaces. Ergonomics is a process that can be beneficially used to address job and workplace design—the human interface with the work system. Improved safety characteristics occur in concert with productivity improvements. Once workers no longer need to devote maximum energy in overcoming the demands of their work practices and/or workplaces, they can devote those same energies to productivity and quality aspects of their jobs."Dr. Ed Bernacki said the statement seemed to have two thoughts. One, that ergonomics is a noun. The other, that ergonomics is a process.
Mr. McCausland explained that the Workgroup was trying to distinguish the noun "ergonomics" from ergonomics hazards, and to identify ergonomics with injury and illness problems, rather than being a process.
Mr. McCausland read the second point, which was changed significantly. He acknowledged that saying the "pursuit of a single definition of MSDs has not reached consensus" was more accurate than saying the "pursuit of a definition has not been productive." He explained the Workgroup’s intent was to suggest that OSHA not let the issue of definitions delay other parts of the analysis. The revised second point read:
"The pursuit of a single definition of MSDs has not reached consensus. Various and numerous MSD definitions cover a host of conditions limited only by those doing the defining, none of which directly help to reduce the number of such disorders. OSHA should continue development of guidelines independent of any final definition of MSDs."Mr. McCausland moved on to the third statement, where he said the Workgroup inserted the idea that MSDs occur as a consequence of exposure to multi-factorial risk and that the objective is to control and reduce the exposure to those risks. The group had made a list of examples rather than an all-inclusive list. The revised third point read:
"MSDs by any definition cannot be exclusively linked into a cause and effect relationship with specific ergonomic solutions. MSDs are a consequence of exposure to risk factors of a multi-factorial nature. The objective of ergonomics applications is to reduce to a practical minimum the demands, for example, physiological, cognitive, behavioral, of doing the work by controlling these exposures. To this end, a number of tools and guidelines may be useful."Mr. McCausland said there was still a discussion about the first sentence of the third point regarding cause and effect. Dr. Orta-Anes wanted it removed from the statement. The Workgroup did not want to remove the statement because they thought that it was true. Mr. McCausland said there was apparently data in some of the NAS reports that more explicitly link the causes of MSDs to particular exposures, but he felt the common understanding is that in general, one cannot exclusively attribute a particular exposure to an MSD.
Mr. McCausland asked Dr. Orta-Anes to explain her thinking on the third point.
Dr. Orta-Anes said she did not find value in the first sentence and did not believe it to be true. She explained that there are two NAS studies that address specific causes and effects of ergonomic problems, which is why she did not feel comfortable with the first sentence.
Mr. McCausland explained that the reason the Workgroup left the first sentence in the statement was to convey that a number of tools and guidelines may be useful regardless of whether or not they have been shown to have a direct link to MSD prevention.
Ms. Susan Sherman suggested changing the first sentence to read: "Not all MSDs by any definition can be exclusively linked into a cause and effect relationship with specific ergonomic solutions."
The Committee had a brief discussion of possible word changes to make the sentence acceptable.
Mr. Goldsmith said the point as written was accurate and it should not be changed. He added that there will always be studies that purport to have discovered a specific cause, but he did not feel any of those reports had been adequately tested.
Dr. Bernacki said he agreed with Dr. Orta-Anes, that the statement was too harsh, even though it has validity.
Mr. Tom Waters from NIOSH suggested the statement begin by saying "The exact cause of a specific MSD may not be known, however…"
Mr. Goldsmith said Mr. Waters’ suggestion might work. He reiterated his previous statement that he didn’t think there was any legally sustainable study that could point out that there is a precise or exact relationship between a cause or effect and an MSD.
Mr. Koskan said that although the idea in the first sentence has been a topic of debate for years, he believed the statement is factual. He said that given Mr. Waters’ statement, perhaps the group had more work to do on the statement.
Mr. McCausland said the Workgroup was willing to continue the discussion on the third point. In regards to Mr. Waters’ comment, Mr. McCausland explained that the reason the group originally said "exclusively linked" was to clearly indicate that an exact relationship does not exist, even if there may be some evidence of a correlation.
Mr. McCausland explained the only change to the fourth point was the removal of "air and noise sampling" since those terms were rather discrete.
Mr. McCausland read the fourth point for the record and then introduced the fifth point, in which the only change was the addition of the words "general health" to the list of examples.
Chair Kerk asked the Committee to table the discussion again to work on the third point.
Mr. Koskan asked if the Committee could accept the rest of the points.
Chair Kerk said it would be cleaner to keep the points as a unit; the Committee disagreed, however, and therefore Chair Kerk asked for consensus on the guidance, excluding the third point. The Committee reached consensus.
Presentation from the Outreach and Assistance Workgroup
Dr. Nelson provided a brief overview of the various activities the Workgroup had worked on during the past 2 years, including:
Ms. Brooks provided details on the modified version of the template for reporting ergonomics success stories, noting that the template was e-mailed to all the Committee members prior to the November meeting. She added that after receiving feedback and incorporating comments, the Workgroup is recommending that OSHA consider the following areas for improving the ergonomics success story collection and distribution process:
Ms. Brooks confirmed that both short- and long-term costs of the programs were included in the data being collected.
Ms. Brooks reminded the Committee that the Workgroup was asking OSHA to consider enhancing the process in any or all of the four suggested ways. She explained that OSHA did not necessarily have to use the exact form created by the Workgroup—it was meant only as a starting point.
Mr. Koskan asked who at OSHA reviews the success stories before publishing them.
Ms. Beth Sherfy of OSHA explained that a law firm in Atlanta is under contract to review success stories. OSHA also reviews the stories before publishing them.
Ms. Susan Sherman, Department of Labor’s legal counsel for NACE, introduced the template into the record as Exhibit 1. She also identified the Workgroup’s two examples of success stories as Exhibit 2.
The Committee reached consensus on the Workgroup’s recommendation that OSHA consider enhancing the success story collection and presentation process.
Presentation from the Guidelines Workgroup (Part III)
Mr. McCausland said the Guidelines Workgroup met with several members of the Research Workgroup, but that they still did not have a full consensus on the third point.
Mr. McCausland read the point for the record:
"MSDs are a consequence of exposure to risk factors of a multi-factorial nature. Control of MSDs cannot always be exclusively linked into a cause and effect relationship with a specific intervention. The objective of ergonomics is to reduce to a practical minimum the demands (e.g. physiological, cognitive, behavioral) of doing the work by controlling these exposures. To this end, a number of tools and guidelines may be useful."Mr. McCausland explained the changes made to the statement.
Mr. Goldsmith said he was not familiar with examples of situations where an MSD can be exclusively linked to a cause and effect relationship with a certain intervention, and he asked for those examples to be put on record along with their source.
Dr. Bernacki asked if the point of the statement was to urge OSHA to come up with multiple tools to discover a link between interventions with the prevention of MSDs.
Mr. McCausland responded that the intent was to indicate that a number of tools and guidelines may be useful in the process of reducing, to a practical minimum, the demands of doing work.
Mr. Fontana said the key is the link between cause and effect, and it is important to emphasize that the cause and effect is unknown in most cases.
Mr. Goldsmith agreed with Mr. Fontana but did not feel that was what the statement conveyed.
Ms. Brooks said she sees the term "cause and effect" more commonly used with hazards causing injuries or illnesses, (in this case, MSDs), than with interventions against those hazards. She said that she interpreted the sentence to say that there are some interventions that may control an MSD. She told the Committee to recognize that the statement had been switched from "cause and effect of hazards of MSDs" to "cause and effect of interventions preventing MSDs."
Mr. McCausland told Ms. Brooks her statement conveyed exactly what the group was trying to say, that no specific intervention can be prescribed to prevent ergonomic injuries.
Mr. McCausland said people at some workplaces are given partial information and believe that if they perform certain actions, the risk of MSDs will be eliminated. The Guidelines Workgroup did not believe that to be the case.
The Committee had further discussion regarding the wording of the statement.
Dr. Nelson said she had a problem with the second sentence [Control of MSDs cannot always be exclusively linked into a cause and effect relationship with a specific intervention], which she said implies that unless a direct cause/effect relationship is established, no other evidence is important. She did not think that statement was true because a variety of different mechanisms have been examined through methods other than randomized control trials. She felt the statement implied that the randomized control trial that determines cause and effect is the only thing of value.
Mr. McCausland said the Guidelines Workgroup agreed with Dr. Nelson, and it is trying to say that, although these things may not have been proven to be exclusively linked in the cause and effect relationships with any specific intervention, a number of tools and guidelines may still be useful.
Mr. McCausland said the Workgroup is specifically staying away from any questions that have to do with ergonomics standards.
Dr. Nelson said the statement would make sense without the second sentence, which she recommended deleting.
Mr. Koskan did not agree with Dr. Nelson because he felt the statement was factual. He suggested the Committee take a vote to see if the majority of the group was willing to accept the wording of the statement. He said he knew some of the Committee members felt it was important to state that this cause and effect relationship does not exist, except in perhaps some specific situation with a very unique control and a very unique exposure.
Ms. Brooks said there are times when certain interventions have eliminated hazards. She also admitted that there might be times when they do not, and the difficulty is in knowing when. She said the challenge was in understanding how people were interpreting the second sentence, and she recommended eliminating it.
Mr. McCausland asked the Committee for another chance to talk with the Guidelines Workgroup in hopes that they might be able to do adjust the wording.
Chair Kerk said the issue would be tabled again and said unless anything changed, there was a motion and a second to delete that sentence.
Assistant Secretary of OSHA, John Henshaw
Mr. John Henshaw, Assistant Secretary of OSHA, arrived and thanked the Committee for their work, noting that NACE had helped OSHA move forward in addressing ergonomics in American workplaces.
Chair Kerk reviewed the Committee’s list of recommendations to date, referring to the handout provided to the Committee. Dr. Nelson also summarized the Outreach and Assistance Workgroup’s progress to date.
Mr. Henshaw provided an overview of the progress OSHA has made on each of the components of the four-pronged comprehensive approach to ergonomics: guidelines, outreach and assistance, research, and enforcement.
Mr. Henshaw noted that OSHA has conducted 1,900 ergonomics inspections since 2002 and has issued 16 citations and nearly 376 hazard alert letters. He added that OSHA has also sent nearly 85 letters to sites acknowledging various organizations’ efforts to reduce workplace MSDs.
Mr. Henshaw said that OSHA has made improvements to its Web site and appreciates NACE’s effort in identifying research gaps and potential industries for future guidelines.
He stated that although the NACE charter is expiring, OSHA will continue to move forward on ergonomics issues and working to reduce the incidence of MSDs. He also summarized the cooperative efforts OSHA has undertaken with its 25 strategic partnerships, including the United States Postal Service. Mr. Henshaw also explained that the Industry Exchange Group between NIOSH and OSHA might soon form a subgroup devoted to ergonomics. In addition, OSHA plans to present at the next National Occupational Research Agenda (NORA) meeting.
Chair Kerk thanked Mr. Henshaw and OSHA for the opportunity to serve the Department of Labor, noting that he had observed the hard work of NACE throughout its charter.
Presentation from the Guidelines Workgroup (Part IV)
Mr. McCausland said it was apparent in the last discussion that the term "cause and effect" had a negative connotation for some people. In order to remove this term, the statement was altered to read:
"MSDs are a consequence of exposure to risk factors of a multi-factorial nature. Other than eliminating the task in question, the effect of any specific intervention cannot be linked to a specific outcome. As such, the objective of ergonomics is to reduce, to a practical minimum, the demands (e.g., physiological, cognitive, behavioral) of doing the work by controlling these exposures. To this end, a number of tools and guidelines may be useful."Dr. Nelson said she appreciated the fact that the group removed the "cause and effect" but the new sentence says the effective intervention and the outcome are the same thing, which is grammatically incorrect.
Mr. Goldsmith agreed with Dr. Nelson and suggested replacing "linked to a specific outcome" with "predicted."
Dr. Nelson suggested saying "an outcome cannot be linked to a specific intervention."
Mr. Fontana said he felt the statement was getting off track from its original intent. He said the original intent was to say that even though the exact cause and effect of MSDs are unknown, the problem should still be fixed.
Chair Kerk asked for consensus on the statement without the adjustments. The Committee did not reach consensus so Chair Kerk asked for a specific plan to modify the statement.
Mr. Koskan suggested incorporating Mr. Goldsmith’s change.
Mr. Goldsmith repeated his suggestion and it was added to the statement.
Dr. Nelson said the statement, with several incorporated changes, now puts the "prediction" and "uncertainty" with "intervention" and changes the intent of the message. She recommended deleting the second sentence, but modifying the first sentence to read: "MSDs are a consequence of exposure to risk factors of a multi-factorial nature, and cannot be easily predicted."
Chair Kerk asked Dr. Nelson if she wanted to eliminate the second sentence. Dr. Nelson said she did.
Chair Kerk asked for consensus on the statement without the second sentence.
Mr. LaPorte agreed, saying the Workgroup addresses the cause and effect issue by bringing up the question of whether ergonomic injuries can be easily predicted.
Chair Kerk asked for consensus on the statement.
Mr. Koskan disagreed, saying the new wording implies that more is understood about the relationship between initiatives and outcomes than really is. He said the new statement is too weak, but he would be comfortable if the idea of eliminating the job was brought back into the sentence.
Mr. Goldsmith suggested replacing the word "easily" with "with any degree of certainty."
Dr. Orta-Anes disagreed saying the current wording recognizes the fact that there are not predictions.
Mr. Koskan asked Chair Kerk to clarify what he meant by consensus, saying there have been times throughout the discussion where a majority could have ruled, but the debate continued in an attempt to get 100 percent consensus.
Ms. Susan Sherman said consensus is general agreement, as opposed to unanimity, which is universal agreement.
Mr. Koskan said, given that definition, he thought the Committee was close to a general agreement a few versions ago.
Ms. Rivera suggested the Committee vote on the statement as is to see where the Committee stood before words were eliminated, per Mr. Goldsmith’s suggestion.
Dr. Orta-Anes agreed with Ms. Rivera, suggesting that the Committee vote on the statement before the latest changes were implemented.
Mr. Tom Waters suggested new wording for the second sentence, which read, (after a few revisions):
"Although the exact cause of specific MSDs may not be known, and the precise effectiveness of an intervention may not be predictable, the objective of ergonomics is to reduce to a practical minimum the demands, such as physiological, cognitive, behavioural, of doing the work by controlling these exposures."Chairman Kirk then read the entire statement which included Mr. Waters’ revised second sentence, as follows:
"MSDs are a consequence of exposures to risk factors of a multi-factorial nature. Although the exact cause of a specific MSD may not be known, and the precise effectiveness of an intervention may not be predictable, the objective of ergonomics is to reduce to a practical minimum the demands, such as physiological, cognitive, behavioral, of doing the work by controlling these exposures. To this end, a number of tools and guidelines may be useful."The Committee reached consensus on the new statement.
The final recommendations for Guidelines as approved by the Committee:
The National Advisory Committee on Ergonomics, at its final meeting, has developed the following points with the intent that they will be useful to guide OSHA concerning the development of future guidelines, outreach and assistance, and research.
Mr. Dave LeGrand, Director of Occupational Safety and Health with the Communications Workers of America, suggested that NACE recommend to Mr. Henshaw a very strong, aggressive enforcement identification and resolution program on behalf of OSHA. He explained that since the revocation of the OSHA ergonomics standard, many companies are determining work-relatedness of MSDs based on Workers’ Compensation data, which is misleading.
Chair Kerk thanked Mr. LeGrand for his comments and asked if anyone from the public wanted to comment.
Mr. Tom Waters thanked the Committee on behalf of Dr. John Howard and NIOSH for allowing them to be involved with NACE.
Chair Kerk adjourned the meeting.