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Holiday Inn on the Hill
415 New Jersey Avenue, NW
May 12, 2004
Dr. Carter Kerk, Chair of NACE, opened the meeting of the National Advisory Committee on Ergonomics (NACE) at 8:40 a.m. on Wednesday, May 12, 2004. Approximately 20 members of the public were present during the course of the meeting. The following NACE members were present:
Chair Carter J. Kerk welcomed the Committee and members of the public to the meeting and called the roll for the Committee members.
Deputy Assistant Secretary of OSHA, Gary Visscher, welcomed the Committee and the public to the fifth NACE meeting. Mr. Visscher thanked the Committee for its work thus far and briefly updated the Committee on OSHA's progress on each of the components of the four-pronged comprehensive approach to ergonomics: guidelines, outreach and assistance, research, and enforcement. He noted that OSHA is very close to issuing final guidelines for both grocery stores and poultry processing plants. In addition, he noted that OSHA is working on guidelines for shipbuilding and shipyards and continues to consider other areas for guidelines.
Mr. Visscher also discussed enforcement as in information matter. OSHA has conducted 1,700 ergonomics inspections since 2002. He added that a majority of the inspections related to nursing homes. OSHA has issued 13 citations and nearly 300 hazard alert letters.
He continued that OSHA has made considerable progress in the area of outreach and assistance. He acknowledged that the Committee has made many useful recommendations in this area, including enhancing OSHA's Web site. OSHA has 56 national alliances, 22 of which are specific to ergonomics. In addition, OSHA has 11 regional alliances relating to ergonomics.
Mr. Visscher discussed the e-tool relating to baggage handling that was improved by working with the alliance with major airlines. He also mentioned that OSHA is working with the Graphics Arts Coalition, the National Telecommunications Safety Panel, and the American Apparel and Footwear Association to develop three industry-specific ergonomics manuals. He added that OSHA is working with other alliances to develop case studies, which could be used at business schools, including Georgetown University.
He discussed the collaboration among three alliances—the American College of Occupational and Environmental Medicine, the American Industrial Hygiene Association, and the American Academy of Orthopedic Surgeons—that are working together on guidance to help determine when upper extremity disorders are work related.
Chair Carter J. Kerk thanked Mr. Visscher. Before approving the minutes from the January 2004 meeting, he asked for any corrections or changes. He noted that he had a couple of grammatical changes and minor corrections to the content. He added that Dr. Audrey Nelson had a few grammatical changes as well. The minutes were then approved.
Chair Kerk then reviewed the charter of the NACE Committee, noting that it ends on the last Saturday of November 2004. He then briefly reviewed the agenda for the day.
Presentation from the Guidelines Workgroup (handouts distributed)
Mr. James Koskan led the presentation for the Guidelines Workgroup. He reviewed the list of 16 industries on which the workgroup felt were appropriate for OSHA to focus, reminding the Committee that the workgroup had discussed its reasoning during the January 2004 meeting.
He indicated that one of the handouts contains a list with a formal explanation of the logic behind each to help answer questions Chair Kerk had received from industry. He explained that the workgroup used data from the Bureau of Labor Statistics (BLS) that had been provided by OSHA. The data listed the manual material handling, or the musculoskeletal disorder (MSD) injury rates for approximately 800 to 900 industries. The group looked at the list and ranked the industries from highest to lowest in terms of injury rate.
Mr. Koskan explained that the workgroup, instead of just looking at the injury rates individually, looked at the size of the businesses or industries using labor hours and factored in this information. He continued that the workgroup then ranked industries by their MSD rate and size to come up with the list of 16 industries. He clarified that the list came up to 19, but OSHA had already selected nursing homes, hospitals, and poultry.
He noted that the order of the industries on the list is not based on severity, but instead on SIC codes.
Mr. Dan McCausland made a few minor formatting corrections to the list noting that the workgroup would provide a corrected list to the Committee members.
Dr. Richard Wyatt asked Mr. Koskan to explain the average rate of 57.5 that is listed. Mr. Koskan responded that 57.4 was the average rate from the entire BLS table.
Mr. Dan McCausland agreed, noting that the workgroup took the totals at the bottom of the table to determine the average of 57.5, which is the MSD incidence rate per 10,000 employees per year.
Mr. Koskan added that in looking over the full list, the injury rates for the selected industries ranges from 72.8 to 206.
Dr. Lida Orta-Anes asked for clarification on the workgroup's suggestion that OSHA use current alliances to access the industries, noting that not all alliances are focused on addressing ergonomic issues.
Mr. Koskan agreed, adding that if OSHA already has a dialogue with an industry through an alliance, there is an opportunity for discussion on ergonomic-related projects, even if it is a new topic of discussion.
Mr. McCausland noted that the workgroup plans to delete the column labeled "points of hours/rate rankings" from the handout because it does not want to include ratings, since the workgroup believes all 16 of the industries should be considered for guidelines.
Mr. Koskan continued with the second point of the Guidelines Workgroup's presentation. He commented that from the outset, the Committee has been focused on research, guidelines, and outreach, and it would appear that NACE will meet the objectives in all three areas by the close of its final meeting.
He continued that the workgroup pondered whether there is more that is necessary relative to a higher-level guideline. For example, should NACE provide more from which to ground future ergonomic initiatives and efforts—some collective perspective on ergonomics that could be used in the future?
Mr. Koskan indicated that the group drafted a statement of fundamentals, as follows:
Mr. Koskan continued:
Chair Kerk asked for the application of these fundamentals to guidelines. He added that if the workgroup has not considered the connection, then perhaps it could take a serious look at the connection between now and the next meeting.
Mr. Koskan responded that he did not think the intent of these five points was to integrate them into a specific set of guidelines, but to establish a framework from which other OSHA projects could use in moving forward.
Dr. Morton Kasdan suggested adding personal attributes or personal health to the fifth point, noting that he thought the statement was excellent.
Mr. Willis Goldsmith asked for clarification on the intent of the statement.
Mr. Koskan responded that the intent of the statement was to make it clear that, based on the information NACE has heard, especially at the last symposium, organizations that have implemented "good ergonomics" initiatives have seen benefits from improved quality, productivity, and energy savings. He continued that some of the research the Committee has seen suggests it is easier to quantify the benefits in those areas than to reduce injury activity. Mr. Koskan acknowledged that the statement was trying to capture a lot and that it could be edited.
Mr. McCausland added that the workgroup views the statement as higher level guidance to OSHA and to the ongoing national discourse on ergonomics, but not specific to any given set of guidelines. He continued that it seemed appropriate, both in terms of guidance for developing guidelines and also as a product of NACE, to try and establish fundamentals about the continued practice of ergonomics.
He emphasized that the handout is only a draft and can be improved.
Dr. Edward Bernacki asked for clarification on the second point, noting that if MSDs are defined without causality, it is not an exercise in futility. If causality is included, such as workplace relatedness, then it is an exercise in futility. He continued that as a physician, it doesn't make any difference how it occurred, you just want that person to get better.
Mr. Koskan answered that depending on who you are―whether you're a physician, insurance company claims examiner, interpreter of a state Worker's Compensation law, ergonomist, or OSHA compliance officer―there seems to be a variety of interpretations of what MSDs are and what can be done to prevent them.
Mr. Corey Thompson reiterated that from a medical perspective you just want to treat, and from a safety and health perspective you just want to identify what caused a risk and eliminate it. He continued that the intent is application, not definition. He added that the statements may need more work to clearly explain the intent.
Mr. Koskan suggested that the Workgroup spend some time addressing the Committee's concerns with regard to the statement. He asked NACE if the group feels a statement of this sort is appropriate.
Mr. George Henschel, Department of Labor's legal counsel for NACE, noted that it would be helpful and more within the range of the elements of the charter to focus the statement on the specific areas that NACE is addressing under its charter, which are research needs, guidelines, and outreach, and not going outside the bounds of the charter in those areas.
Mr. Paul Fontana commented that the statement does fit within the scope of the charter because it deals specifically with guidelines. In particular, he noted that the second point addresses the Committee's discussion over the last five meetings about what MSDs are. He continued that until some higher body adopts a definition and says 'this is, for OSHA's purpose, what an MSD is,' what we're saying is, from an ergonomics perspective, we need to move on.
Dr. Orta-Anes congratulated the group on their efforts. She recommended that the workgroup work on the language and consider the possibility of the other two workgroups contributing to the next draft.
Ms. Lisa Brooks agreed with Dr. Orta-Anes. She indicated that she likes the overall concept of the statement, but needs time to seriously consider and wordsmith it and think through how it might be interpreted.
Dr. Nelson commented that it was still unclear why the statement was developed. She asked the Guidelines Workgroup for a goal or purpose statement to help her understand the document and its uses.
Chair Kerk summarized that it appeared NACE found some value in it, though it needs a little more work and a little more clarification. He emphasized the need to make sure the Committee keeps it within the scope of the NACE charter as much as possible, but the Guidelines Workgroup should continue to work on it. He added that there are similar types of discussions going on in the other workgroups.
Mr. Koskan concluded that the Guidelines Workgroup will revisit the language and see what it comes up with, taking into consideration what the full Committee has discussed. He added that the workgroup heard consensus that the concept is valid.
Presentation from the Outreach and Assistance Workgroup (handouts distributed)
Dr. Audrey Nelson gave an overview of the four issues the Outreach and Assistance Workgroup planned to discuss: collaboration with the American Society of Safety Engineers (ASSE); an Early Adopters program; success stories; and the concept of a Best Practice Forum.
Dr. Nelson reminded NACE that the workgroup did get an endorsement from the full Committee during the January 2004 meeting to start collaborations with ASSE and assess where there might be mutual areas of interest.
Referring to an abstract summarizing ASSE's work relating to building a business case for ergonomics, she explained that while the workgroup did not have time to review the material in depth, the workgroup has set up a conference call to discuss next steps internally.
Dr. Nelson then discussed the Early Adopters program and the organizational outline described on the handout, reminding the Committee that it approved the concept of an Early Adopters program at a previous meeting. Dr. Nelson explained that the goal of the program is to promote dissemination and early adoption of OSHA guideline recommendations. She continued that when a guideline is first released, there should be incentives to encourage people to implement them in a timely fashion and collect evaluation data that can help others.
Dr. Nelson explained that the workgroup had discussed several methods, including a competitive grant process timed with the release of the guideline. Using a similar review process that OSHA already has in place-for example, one used by the Susan Harwood grants-would be one possibility. The grant would cover the cost of the evaluation, not the costs associated with implementing the guidelines, which the industry should be providing.
She emphasized that current early adopters may be doing some of this implementation, but they do not take the time and do not have the resources to do a good, solid evaluation, which would help facilitate implementation of the guidelines by others. She recognized that the funding per award would be set by OSHA, but noted that funding in the range of $5,000 to $20,000 would cover the cost for the evaluation component depending on the size of the organization and the scope of their implementation plan. The evaluations would be written using the existing success story format.
To obtain a critical mass of early adopters, the workgroup recommended funding somewhere in the range of 10 to 12 grants in Year 1 and Year 2, which would mean that implementation needs to be completed in one year or less. She added that the concept of early adopters is to make t he evaluation data available to others as soon as possible.
Dr. Nelson reiterated that the workgroup is recommending that OSHA adopt the concepts of the Early Adopters program, recognizing that, depending on fiscal and other organizational issues, it will make it its own and decide how best to get it implemented within the organization.
Ms. Lisa Brooks continued the presentation, providing information on the success stories template. She explained that the goal of the workgroup’s effort with regard to the success story template was to increase the number, quality, and use of the ergonomic success stories posted on OSHA's Ergonomics Outreach and Assistance Web site, as well as to provide a mechanism for collecting data on the business case for ergonomics.
She continued that the template is meant to provide the maximum benefit in terms of complete and useful information, as well as the ability to transfer the information in the success stories. At the same time, it should minimize the burden of the collection process on the person providing the information, as well as for OSHA, in terms of organizing and posting.
Ms. Brooks explained that the workgroup spent additional time between the January 2004 meeting and this meeting refining a previous template, which is included in the handout.
She described the importance of some of the components in the new template, including the ability to search using select criteria. The search criteria the workgroup felt were the most important included:
Ms. Brooks indicated that the workgroup suggests that the full NACE Committee recommend that OSHA adopt the success story template (both the template and the process), including the search capabilities, and that this be used to facilitate the sharing of best or effective practices.
She continued that the second action the workgroup is proposing to the Committee is that OSHA should solicit success stories through current and future alliances.
Dr. Nelson continued to present information on the concept of a Best Practice Forum. She reminded the Committee that at the January 2003 NACE meeting, OSHA posed the question of whether a Best Practice Forum would be a plausible method for disseminating information. The workgroup discussed the idea and decided that general Best Practice Forums related to ergonomics would be less useful than industry-specific Best Practice Forums in terms of really getting the points across. She continued that timing is very important; to be opportunistic and take advantage of guidelines, the ideal time to have industry-specific Best Practice Forum would be one to two years after the guideline is released.
Dr. Nelson outlined action items related to the Best Practice Forum, including promotion. She noted that OSHA does not have to hold the forums, but the workgroup recommends that OSHA help promote the concept through existing collaborations with its education centers, regional offices, existing VPPPA groups, as well as the alliance programs and industry associations.
She also described the idea of developing a best practice tool kit that would illustrate how different partners or collaborators could hold a best practice forum in conjunction with an annual meeting or conference. The tool could summarize the stages and the steps of putting this together to make it easier for these other groups to implement forums into their existing formats.
She concluded that the workgroup also recommended that OSHA collect the best practices being presented at industry-specific conferences across the country, noting that it would take very little effort to encourage these presenters-poster presenters, paper presenters, etc.-to put their information into a success story format so that OSHA can post them on the Web site.
Mr. Willis Goldsmith commented that the success story submission template and the industry-specific best practice forums present an interesting juxtaposition. He continued that his concern with regard to the success story submission template is that there is no way to test the validity of anything that is submitted. He suggested that some kind of disclaimer be put on the form to indicate that submissions cannot be attributed to the position of the Department of Labor, OSHA, or anybody else.
He continued that the best practice forums are a different matter because there are people providing evidence and describing what they have done, and there may be questions about what is being said. Mr. Goldsmith reiterated that he is concerned that there will be a lot of invalid, unsubstantiated information that may, in the end, be quite misleading.
Mr. James Koskan agreed with Mr. Goldsmith’s concern, suggesting that one way to reduce the potential for invalid or misleading information is to examine the process by which someone submits a best practice. He added that if there were a couple examples of what a good submission looks like, it would address the issues of clarity, description of the problem and the solution, and the impact it had in measurable terms. That way the submitter would know what kind of information OSHA is looking for.
Mr. Koskan continued that he agreed that people coming out of the Early Adopters would probably be great candidates for the success story template.
Dr. Richard Wyatt responded that the workgroup had discussed these issues and agreed that as part of the success story database, the workgroup would need gatekeepers to review the information and ensure it is written in a consistent manner. He added that there would be some oversight of the data, so that not just anybody could enter information into the database.
Ms. Lisa Brooks added that there is currently a disclaimer on the Web site, and that it would need to stay. She reiterated that the workgroup discussed the same issue and acknowledged the importance of validating the information through a review process. She continued that there currently is a screening process for the posting of success stories, so this process would continue, and the disclaimer would be an important part of that.
Dr. Lida Orta-Anes asked the workgroup to consider including before and after pictures as part of the template. She added that in regards to the success story categorization, she would like to see the types of tools used to show how others are identifying and documenting the risk factors.
Ms. Brooks responded that the workgroup agreed and included information on photos in the description. She also noted, in response to Mr. Koskan’s earlier comment, that the Early Adopters participants would probably be great candidates for the success story template, that the workgroup thought the collection of success stories could be coordinated with Best Practice Forums and the Early Adopter programs. She added that perhaps it could be strongly encouraged in the Early Adopters program that they would have to submit some success stories to be eligible for the grant.
Mr. Goldsmith reiterated his concern that the quality of the information cannot be validated. He asked for information on the current screening process for success stories.
Ms. Beth Sherfy, Office of Outreach Services and Alliances, OSHA, explained that her office is responsible for collecting and posting the success stories that are currently on the ergonomics Web page. She continued that her staff solicits success stories―some through the alliance program participants and others just through interested parties. Once they obtain the name of a company that has expressed interest in providing information to us, they have a third party contractor—a law firm out of Atlanta—contact the organization and interview the people there. They then verify the information and write the success story, which is reviewed by the company providing the information. She added that OSHA then reviews the information and if there are additional questions they resubmit it to the contractor. She concluded that once OSHA is satisfied with the content, it is posted to the Web site.
Mr. Goldsmith commented that the process is commendable. He asked whether her office would be able to handle the collection of success stories, financially or otherwise, if the program is substantially enlarged to include all manner of other success stories.
Ms. Sherfy replied that if the program is substantially enlarged, they will have to address that issue; however, they are currently not overwhelmed with success story submissions. Instead, they hope that NACE's work will increase the flow of information. She added that her office is impressed with the quality of the current success stories collected.
Mr. Goldsmith asked for the wording of the disclaimer. Ms. Sherfy could not remember the exact wording, but noted it was developed by the Solicitor's Office. She added that the disclaimer is posted on the success story Web page.
Dr. Morton Kasdan asked if an epidemiologist reviews the submissions to determine if the data are valid from an epidemiological or scientific standpoint.
Ms. Sherfy replied that they are not reviewed.
Dr. Audrey Nelson commented that best practices are more towards the consensus part of the evidence continuum (with scientific evidence on one end and expert opinion consensus on the other). She continued that this is not at the level of a peer reviewed scientific journal, but it still serves a useful purpose.
Mr. Paul Fontana agreed with Mr. Goldsmith's concerns and also with Dr. Nelson's standpoint. He continued that he encourages NACE to expand beyond the OSHA Web site and target industry-specific publications, journals, and Web sites, because small businesses read these types of resources.
Dr. Wyatt suggested the workgroup provide several examples of the types of information they are hoping to disseminate to present to the full Committee at the next meeting. He also reminded the Committee that at the January 2003 NACE meeting they discussed practical application of ergonomics, which is precisely what the success stories represent.
He responded to Mr. Fontana noting that Web sites are one way to disseminate information, but there are many other methods, such as CDs and written correspondence.
Ms. Brooks added that the workgroup wants to collect submissions if it has information that can be transferred, even if it can only impact a couple of key areas. She continued that it was an important part of the process to encourage submissions.
She explained that the advantage of being on one Web site, such as OSHA’s, is that the stories can be searched for select criteria. As additional success stories are identified, OSHA could add those links to its Web site, and work with the different industries to link back to the OSHA Web site.
Mr. Dan McCausland asked whether the workgroup had discussed why anybody would want to submit a success story and what the value is to submitters. He asked whether the workgroup or OSHA should consider providing incentives to people.
Chair Kerk asked Ms. Sherfy if collecting best practices or success stories is one of the negotiated items in the partnerships and alliances that OSHA already has in place.
Ms. Sherfy replied that she is not involved with OSHA's strategic partnership program, but participants are required to provide various data. With regard to the alliance program, OSHA often makes program participants aware that it is collecting these success stories.
Mr. Goldsmith emphasized his concern about offering incentives to people for submitting success stories. He also commented that he disagreed with Dr. Nelson's description of the continuum of evidence. He continued that his real concern is that at some point in the futue, if there is another standard that is promulgated, all of a sudden there is going to be a compilation of best practices taken from the OSHA Web site to indicate that some particular method is an appropriate way to abate a particular condition.
Ms. Brooks responded to Mr. McCausland’s question about why people would submit success stories, explaining that the workgroup first tried to make the submission process easier. She continued that there are still some who, for various reasons, do not want their information published on the OSHA Web site. However, there are a lot of organizations that do want a positive relationship with OSHA and are not scared of posting something on its Web site. So the workgroup has targeted these organizations.
Mr. Koskan, referring to the estimated $5,000 to $20,000 grant per organization evaluations of the Early Adopter's program, asked how the workgroup proposed funding it and whether OSHA would have funds available to cover the cost.
Dr. Nelson commented that the workgroup was told that it should not constrain its recommendations to zero funding level, and that the idea would just be submitted to OSHA as a recommendation. She added that they could change or coordinate budget issues as needed.
Chair Kerk asked for consensus from the full Committee on the recommendation to OSHA to adopt the concepts of the Early Adopters program, taking into consideration the comments that came out of the discussion.
Mr. McCausland asked for clarification on exactly what would be forwarded to OSHA.
Dr. Nelson responded that the workgroup worded the handout a bit vaguely because it realized that there are funding implications and that the concept would ultimately be shaped somewhat by OSHA. Therefore, NACE would forward the documents and the minutes of this discussion to OSHA, which would then decide how to use it.
Chair Kerk confirmed with Mr. George Henschel that NACE would be approving the concept and attaching the documents as a template for what OSHA could do.
The Committee reached consensus on the concept of the Early Adopter's program.
Dr. Nelson continued that the workgroup was asking NACE to recommend that OSHA adopt the success story template, including the search capabilities, and a format to facilitate the sharing of these best practices. In addition, OSHA should solicit success stories through future and current alliances to increase the number of submissions.
She noted that the workgroup discussed coming up with some examples to include.
Mr. Fontana suggested that since there are some minor changes, NACE should wait until the next meeting to approve the template and forward it to OSHA. That would give the workgroup time to provide examples and add additional categories to the search criteria.
Dr. Nelson reiterated that once the concept is approved and forwarded to OSHA, the Committee could ask OSHA to also look at the minutes and capture the richness of this discussion.
Chair Kerk clarified that there was no consensus and that the workgroup should continue to work on the template for the November 2004 meeting. He also encouraged the full Committee to take the opportunity over the next few months to visit the OSHA Web site, study the success stories available, and become familiar with the Web site so they are more knowledgeable for the next meeting.
Dr. Nelson continued that the Workgroup was also asking NACE to approve the recommendation regarding the Best Practice Forum, specifically:
Mr. Fontana asked whether OSHA currently holds small conferences on best practices. Dr. Nelson responded that it has in the past.
He asked whether this recommendation was to encourage OSHA to hold industry-specific forums or general ones. Dr. Nelson clarified that the workgroup believes that industry-specific forums are more valuable than the broad based ones.
Dr. Nelson clarified the third point, noting that it is separate from the changes to the success story template discussion that was tabled until the November 2004 NACE meeting.
Mr. McCausland asked whether OSHA would have to attend the conferences.
Ms. Brooks answered no, explaining that the workgroup was not recommending that OSHA be at every conference to collect success stories, but that the information presented at these conferences be used to publicize that OSHA is collecting success stories for its Web site.
She added that the workgroup had communications with the organizers of the Applied Ergonomics Conference, and they are strongly interested in taking the submissions from their ergonomics competition and having them be submitted as success stories for OSHA.
Mr. Goldsmith asked for clarification on the difference between success stories and best practices.
Dr. Nelson clarified that the group had taken the word "template" out of the recommendation. OSHA already has an existing success story format, so this fits in with their existing format.
Ms. Brooks strongly encouraged everyone on the Committee to review the OSHA ergonomics Web site―the outreach section and the success stories―to clarify several of the issues that have been discussed.
Dr. Nelson asked for a point of clarification, noting that there is a lot of discussion over the wording of each recommendation. The bottom line is, NACE is just making a recommendation to OSHA and the final documents will not turn out to be the way they are right now. She asked for guidance on how these recommendations should be worded.
Mr. Henschel responded that the group should provide general guidance, including more specific examples of what it has in mind, if the idea is to provide OSHA with considerable flexibility as to how to implement these recommendations. He added that if there are particular elements that are not as easy to incorporate as others, they could offer various options or alternatives.
Chair Kerk asked for consensus on the best practice forum action item.
The Committee reached consensus on the concept of the best practice forum.
Comments from the Public
Mr. Bill Kajola, Safety and Health Department of the AFL-CIO, suggested adding "outcomes" to the search criteria for the success stories. He added that under the Early Adopters program he would suggest using some of the funding to set up some criteria to ensure that the outcomes are, indeed, valid. He also recommended the Guidelines Workgroup strike number two from the statement of fundamentals.
Mr. Richard Strain, Chairman of the American Academy of Orthopedic Surgeons Occupational Health Committee, commented that he was happy to see people raise the level of science with respect to some of these issues, emphasizing that as NACE starts making recommendations, it should realize that the level of evidence is extremely important when evaluating the issues.
Presentation from the Research Workgroup
Dr. Edward Bernacki led the presentation for the Research Workgroup, noting that the workgroup also grappled with definitions. He discussed the specific recommendations relating the research gaps, including the need to:
Mr. James Koskan asked whether the third point focused on psychosocial factors limited to just the workplace, or beyond the workplace to other non-work related psychosocial factors.
Dr. Bernacki replied that the focus was on psychosocial factors.
Mr. Willis Goldsmith agreed, adding that any study of the psychosocial factors that impact those conditions is going to go beyond the workplace.
Dr. Audrey Nelson asked for clarification on whether the recommendation is that OSHA should conduct these studies or that OSHA should accept this list of gaps in research.
Dr. Lida Orta-Anes responded that the workgroup is suggesting that OSHA adopt the recommendations over which it has jurisdiction, and transfers recommendations that are the jurisdiction of other entities, such as NIOSH.
She continued that the workgroup has identified research gaps, noting that most of these issues are common themes discussed in the other sources.
Mr. Koskan reiterated his question about how the workgroup is addressing the non-work related components of the MSD problems that are identified in the workplace.
Dr. Morton Kasdan replied, paraphrasing Susser, an epidemiologist, who said that when you're attributing a something like a disease to the environment, you have to look at all aspects of the environment. He added less time is spent at work than is spent outside of work.
Dr. Nelson asked for information on the process the workgroup used to come up with the identified gaps. She added that the reports that were used as sources all have a long list of identified gaps, so she wondered how the Workgroup took long lists and came up with this small number of recommendations.
Dr. Orta-Anes first responded to Mr. Koskan, explaining that the workgroup recognizes that psychosocial factors are an important component that needs to be addressed, but it is not giving any specific guideline to OSHA in that regard because it's really beyond the scope of OSHA's charter to do that.
She continued, responding to Dr. Nelson's question, that the workgroup divided the different types of sources and tried to summarize the different types of recommendations.
Dr. Bernacki added that the list of recommendations reflects common themes that came through when they synthesized the information, emerging as the big gaps.
Mr. Koskan reiterated that he would like to see something that was more focused on trying to identify the impact of non-work related activities and how to define the effect that these activities had on the occurrence of MSDs in the workplace, within the framework of those recommendations. He mentioned that Dr. Tom Waters had identified five gap areas during the January 2003 NACE meeting; the fourth one was the role that individual factors, such as genetics, obesity, and gender, play in this whole area.
Dr. Tom Waters suggested that the seventh recommendation refers to non-work related activities, by referring to different factors. For example, they could be genetics, or they could be psychosocial.
Mr. Fontana suggested that including the term "non-work related" multifactorial would satisfy their concern.
Dr. Orta-Anes read the corrected version back to the full Committee: "Conduct studies focused on interactions of the acknowledged occupational and non-occupational multifactorial causes of diseases and injuries, including, but not limited to those of the upper extremity and lower back."
Ms. Lisa Brooks asked for a definition of the term 'natural history,' referred to in point number eight.
Dr. Waters responded that they are referring to the natural history of a disease—from the very beginning when people might start having symptoms, to actual measurable health outcomes, all the way to disability, and then compensation.
Ms. Brooks also asked why each slide stated "upper extremity and lower back disease and injuries," but did not narrow it to MSDs. She asked whether the research gaps focused on musculoskeletal, or were they broader.
Dr. Waters responded that each slide should read "musculoskeletal, including, but not limited to, lower back and upper extremity."
Dr. Orta-Anes explained that the workgroup discussed the terminology extensively and decided not to use the term MSDs, but instead use "diseases and injury of the upper extremity and low back." She continued that the workgroup felt there was not yet a final definition for MSD and so it felt more comfortable with the other description.
Dr. Morton Kasdan commented that he'd rather cast a wide net that physicians understand because, as far as he knows, the surgeons sitting in the room do not know what MSDs are because they don't involve nerves or vessels.
Dr. Nelson reiterated her suggestion that the workgroup clarify that the Committee should be taking action on endorsing this list of identified research gaps. She commented that she didn’t think that each one of the points should be a separate recommendation on which OSHA would conduct research. She suggested clarifying the wording of the recommendations.
Dr. Waters suggested altering some of the language to make the recommendations clearer.
Mr. Fontana agreed with Dr. Nelson, noting that if the Committee's charge was to identify research gaps, the recommendation should clearly state that the NACE Committee identified these research gaps, listing all five of them, and then take the last recommendation as a separate request.
The Committee took a short break to give the Research Workgroup time to adjust the wording of the recommendations.
Dr. Orta-Anes explained that the workgroup rephrased and reformatted the recommendations. She reread the revisions:
She continued that in reference to Ms. Brooks' question about using the term "upper extremity" and "low back," the workgroup included the definition adopted by the American College of Occupational and Environmental Medicine, and organized by ANSI Z365, a greater standard committee. Specifically, it reads:
"Musculoskeletal Disorders, MSDs: Disorders characterized by an abnormal condition of the muscle, tendon, tendon sheath, nerve, bursa, blood vessel, bone, joint, or ligament, resulting in altered structure or impaired motor or sensory function."Mr. Goldsmith clarified that the definition was not written down yesterday, and that it was only included in the presentation for informational purposes.
Mr. Koskan asked for clarification on whether the focus of the discussion is to agree on the research gaps or the definition of MSDs. Dr. Orta-Anes clarified that the main target is to look at the research gaps.
Dr. Nelson asked to revisit the wording of the musculoskeletal disease issue because, while there may be some ambiguity in how people define it, the definition that is displayed is very broad and is subject to ambiguity. She suggested using a term people are familiar with―musculoskeletal disease―adding a footnote that clarifies the definition.
Mr. Goldsmith reiterated that there is ambiguity in the definitions, and the reason the workgroup did not use that definition, and instead used upper extremity and lower back, is because it was more specific. He continued that he did not think NACE should adopt anybody's definition of musculoskeletal disorders.
Mr. Koskan agreed, noting that one of the research gaps in the recommendations was coming up with a definition, so, in a sense, one of the research gap recommendations is to address this issue.
Ms. Brooks clarified her original question, noting that the current phrasing, though meant to be more precise, is not. She explained that if it is too vague, it could be misinterpreted.
Mr. McCausland agreed, noting that the nine points that have been identified by the workgroup as research gaps are excellent, but the workgroup is at risk of defeating its intention because it is using a definition of MSDs on which people will not agree.
Ms. Barbara McCabe noted that all of the recommendations are made with the assumption that they are geared toward the mission of this Committee, only in regards to ergonomics.
Dr. Nelson suggested altering the language in the opening statement discussing research gaps. She suggested adding the term "ergonomics" and deleting "including, but not limited to, the upper extremity and lower back," in the individual recommendations.
Mr. Goldsmith commented that this solution creates another question as to the definition of ergonomics. He suggested the workgroup take the comments back and revise its recommendations.
Dr. Kasdan explained that he does not want a term to describe injuries and illnesses. Instead, they should be labeled what they are, for example carpal tunnel syndrome, rotator cuff injury, etc.
Dr. Waters commented that people in the research, science, and medical communities use an exact term. The insurance people want an exact term. He continued that perhaps "musculoskeletal disorders" is not the right term, but if it isn't, then this group could come up with one.
Chair Kerk suggested the workgroup continue to discuss these issues and send them to the full Committee prior to the November 2004 meeting so NACE would have time to review and comment.
Ms. Roxanne Rivera commented that in order for the group to continue to work on it, it needs to know if the rest of the Committee agrees with what is contained within these nine gaps. Wording aside, does it concur that these are indeed research gaps?
Mr. McCausland suggested the workgroup consider incorporating a section of the charter into the list of recommendations. He continued that if they could get some language that in the root statement before the list of nine research gaps, they could remove the references to upper extremity and lower back disorders and MSDs.
Dr. Bernacki noted that the suggestion introduces a new dimension, since the nine recommendations currently stand on their own.
Chair Kerk summarized the discussion, noting that the Committee likes the nine points but would like to see them presented in a different way. He continued that the contention relates to whether to call it an MSD, upper extremity, lower back, or something else.
Mr. Goldsmith suggested using the phrase "research gaps identified pursuant to the NACE charter include:" in the stem statement.
Dr. Nelson suggested that, in reference to recommendation regarding definitions, the workgroup consider recommending a consensus conference to come up with definitions of the 9 or 10 terms that are extremely problematic. She commented that it would be the Research Workgroup's responsibility, since the science is not going to move forward until there is some consensus as to what is being discussed.
Chair Kerk concluded the discussion by sending the recommendations back to the Research Workgroup to have them discuss them more, with a plan to have them circulate the recommendations to the Committee well in advance of the November 2004 meeting.
Mr. Henschel, introduced the following exhibits into the record, noting that a number had been superseded by later versions, which will also be put into the Docket:
Mr. Bill Kojola, suggested using a term that comes out of the NACE charter to help solve the discussion relating to the Research Workgroup's recommendations. Specifically, he suggested using "ergonomics-related injuries and illnesses."
Chair Kerk thanked the Committee for their work and reminded members that the next meeting will be held on November 16-17, 2004, in Washington, DC. He briefly discussed possible options for the format of the meeting and then adjourned the meeting.