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The meeting of the National Advisory Committee on Ergonomics (NACE) was opened by Dr. Carter Kerk, Chair of NACE, at approximately 8:30 am on Wednesday, September 24, 2003. Approximately 30 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 introduced MaryAnn Garrahan, Occupational Safety and Health Administration (OSHA), as the designated federal official for the meeting. Chair Kerk briefly restated the five goals of NACE:
Chair Kerk asked for approval of the minutes from the May 6-7, 2003 meeting.
Dr. Morton Kasdan had a correction to page 4 stating that it should read, “For example, the ANSI Z365 committee has only 2 experts from the 55 members who are familiar with anatomy, physiology and pathology of the upper extremity and treat these patients.”
With that change the committee approved the minutes of the May 6-7, 2003 meeting.
Assistant Secretary of OSHA, John Henshaw thanked the committee for their efforts and offered a review of OSHA’s four-pronged approach to ergonomics. Mr. Henshaw updated the committee on OSHA’s guideline work, emphasizing that OSHA’s approach is to provide voluntary guidelines that describe common problems in specific industries and present effective workplace-tested solutions. Mr. Henshaw stated that OSHA would not use ergonomic guidelines as a basis for citing employers who fail to address musculoskeletal disorders (MSDs) in the workplace. The timing of the inspection program for nursing homes and the issuance of voluntary guidelines was purely coincidental. The guidelines are meant to offer useful information on ways an industry can address ergonomic problems.
Mr. Henshaw added that OSHA intends to develop more guidelines and is looking to NACE to recommend which industries are in need of guidelines and what areas OSHA should approach for future guidelines.
Mr. Henshaw gave an update on outreach and assistance, noting that OSHA is forming alliances that focus on ergonomics. Of OSHA’s 32 national alliances, 16 address ergonomics specifically. For example, as part of an alliance with the American Industrial Hygiene Association (AIHA), three OSHA staffers participate as ad hoc committee members on the AIHA Ergonomics Committee, enabling better information exchange on ergonomics. OSHA is also working with the airline industry alliance to improve its baggage handling. An e-tool is available to help the nation’s 50,000 airline baggage handlers avoid injuries. There is also a biomechanical training module in the works that will be available free of charge to OSHA and all of the airlines for employees handling checked baggage. Both the Independent Electrical Contractors and the Dow Chemical Company have agreed to form alliances with OSHA to work on industry-specific ergonomic issues.
OSHA has announced 10 Susan Harwood grants focused on training on OSHA ergonomics guidelines in nursing homes, poultry processing, and retail groceries. In addition, OSHA has 20 education centers and has scheduled 47 different ergonomics training classes to raise awareness about how to address problems in industries and facilities. OSHA has also posted a new computer work station e-tool on its Web site to help find practical solutions that can be applied to work stations around the country.
Mr. Henshaw discussed the research component of OSHA’s four-pronged approach. OSHA looks forward to NACE’s recommendations about holding a symposium to gather published research about the most challenging topics in ergonomics.
Mr. Henshaw touched on enforcement even though it is not part of the NACE charter. OSHA has stated that facilities that are making good-faith efforts in addressing ergonomics will not be targeted. OSHA has conducted 1,376 inspections on ergonomics and issued hundreds of hazard alert letters. OSHA has issued 11 General Duty Clause citations to eight facilities; all but two were settled or are in the process of being settled. Mr. Henshaw recognizes that not all facilities are equal across the board, even at the same company. Therefore, enforcement is facility-specific.
Dr. Richard Wyatt asked Mr. Henshaw to discuss the metrics used to determine the inspections. Mr. Henshaw stated that it was mostly incident rates. About 1,000 nursing home emphasis programs were selected due to the high injury rates dealing with MSDs. Ergonomic inspections were determined by the number of injuries and illnesses, or lost time injuries due to MSDs. Dr. Wyatt asked if there was a break-even point. Mr. Henshaw noted it was part of OSHA’s site-specific targeting process, which is triggered by lost time injury rates.
Dr. Kasdan asked if there has been any change in the number of deaths on the job, excluding September 11, 2001. Mr. Henshaw replied that overall the results have been promising. The Bureau of Labor Statistics (BLS) report of the 2002 figures showed a 6.6 percent reduction in the number of fatalities. The numbers in 2001 showed a fatality reduction of about 10 or 20. In 2002 there was a fatality reduction of over 400. The rate went from 4.4 to 4.0.
James Koskan asked for clarification about the process for deciding when to move forward with a citation. Mr. Henshaw explained the three phases. First, OSHA gathers data through normal inspections that take place in OSHA’s area offices via scheduled inspection programs or through referrals or complaints. Second, OSHA (at an appropriate level) will review with the Solicitors and regional Solicitor’s Office, as well as the OSHA office, to determine the need for another review by external experts familiar with a particular situation. Finally, all cases are reviewed in Washington by OSHA and the Solicitor's Office before an Area Office issues a citation.
Lisa M. Brooks asked about the separation between guidelines and enforcement. Mr. Henshaw repeated that guidelines are not to be used for enforcement. In order to determine whether there is a good-faith effort in a facility, an inspector looks at the injury rates and lost time injury rates and discusses with the facility what they are doing in response. A facility that is working on a solution and producing results, and has reason to believe it could produce results, is exercising good faith. A facility that continues to have injuries and illnesses and does not identify solutions when there are solutions available may be a candidate for a citation. When a citation is written, OSHA suggests possible solutions from a variety of sources, not just the guideline that has been developed.
Presentation by Dr. David Wegman
Dr. David Wegman, MD, MSc, Dean of the School of Health and Environment at the University of Massachusetts Lowell, gave a presentation summarizing a report published by the National Research Council Institute of Medicine’s panel on musculoskeletal disorders in work (see Exhibit 1). The charge of the panel was to:
Dr. Wegman gave an overview of the study, highlighting the conclusions that came out of the report.
Mr. Koskan asked Dr. Wegman to characterize the balance and relationship between work-related versus non-work-related factors. Dr. Wegman acknowledged that there is no excellent answer because it is difficult to separate the two in a way that allows you to look at the magnitude of each. Because most of the adult population works, there is not a background non-work population that can be used as the constant. However, older populations are more susceptible to MSDs independent of specific risk factors and there are some gender differences that are related to biological factors. In addition, it is clear that people with a heavier body index have a greater risk. The evidence reviewed for this study did not give a reasonable answer to the question.
Mr. Koskan asked whether these issues should be discussed in a public health forum and not just within the work environment because there is a connection between MSDs and non-work-related lifestyle issues, as well as some workplace factors. Dr. Wegman responded that the committee did not come to a conclusion on that issue and was instead charged with looking at the workplace factors and identifing those where interventions in the workplace might make a difference. However, Dr. Wegman did agree that there are other places to discuss the issue.
Mr. Willis J. Goldsmith acknowledged that one of the frustrations of people on the industry side of this issue is the lack of clear and consistent end point measures, as was discussed in Dr. Wegman’s presentation. Mr. Goldsmith asked Dr. Wegman to expand upon this idea and clarify how a company knows when it has done enough. For example, if the research to date does not have clear and consistent end point measures, what can you do if you are trying to do the best you can in a workplace? Dr. Wegman clarified that there is not an absence of useful endpoint measures or a consistency across end point measures. Instead, there is some clarity and consistency, and an understanding about the need for improvement. Dr. Wegman acknowledged the frustrations of people on the front line and admitted that the panel did not come up with an answer as to what is “enough.”
Mr. Goldsmith asked for clarification regarding the attributable fractions that were included in Dr. Wegman’s presentation and how their use reflects the significance of various factors. Dr. Wegman explained that the attributable factor is a relative term and although it is quantified, you should not try and interpret the actual number. You cannot compare them as actual numbers. Instead the numbers give you a relative idea of the importance of the risk factors of a certain workplace. The message the panel tried to address is that there is an opportunity in the workplace to intervene on certain items, regardless of the other factors that exist. The attributable factors are only an attempt to stack up their relative value.
Mr. Goldsmith asked for clarification of definitions and how people on the front line understand and apply terms such as “heavy,” and “repetitive.” Dr. Wegman admitted that the report helps identify the importance of finding good definitions for those terms and that these characteristics are areas that need more attention.
Dr. Edward Bernacki asked for information on how the committee dealt with psychosocial factors, in particular the issue of self-reporting. Dr. Wegman agreed that some of the psychosocial outcomes are self-reported, but added that some are observational or around organizational factors. There are few studies that have examined the interaction of psychosocial factors and physical factors, and it is difficult to examine one without the other. This might be an area that should have further research in the future.
Dr. Kasdan noted his concern that so much literature fails to acknowledge the reimbursement schedule for physicians and how it varies between Worker’s Compensation and non-Worker’s Compensation. Dr. Wegman responded that the report did not cover that topic.
Mr. J. Dan McCausland asked whether attributable factors could be applied to the individual characteristics that affect vulnerability to work-related MSDs and whether there was anything in the report that examined the relationships between those characteristics. Dr. Wegman clarified that the attributable fraction is designed to address individual factors, which made it difficult to apply to multiple factors. It is possible to do so, but the study was not looking at the factors independently.
Ms. Roxanne Rivera asked if any allowances were made for false Worker’s Compensation claims. Dr. Wegman explained that the panel was looking at studies of claims, not the individual claims, so it could be assumed that false claims were not included in the studies.
Ms. Barbara McCabe asked about examining psychosocial factors in relation to both regions and industries. In particular, whether there is any under-reporting or over-reporting in various industries that may be considered “macho” or “non-macho.” Dr. Wegman stated that the panel was concerned about national data because there are differences between regions, industries, and even within industries.
Dr. Bernacki asked Dr. Wegman to discuss the greatest research gaps. Dr. Wegman responded that there is a significant research gap regarding the interaction of psychosocial factors and physical factors. In addition, there is a need for intervention effectiveness research, as mentioned by Mr. Goldsmith. Intervention research is difficult to implement because you cannot randomly apply an intervention to industry. Industry, labor groups, the government, and the private sector should work together to collaborate on intervention studies.
Ms. Brooks asked how the panel concluded that there are appropriate interventions that exist to reduce work-related MSDs. Dr. Wegman responded that the conclusion was based on a mix of formal intervention studies, case studies, and panel discussions, which are covered in detail in the final report.
Ms. Rivera remarked that poor job satisfaction could contribute to non-work related issues other than lower back pain, such as cancer and divorce. Dr. Wegman offered his personal opinion that job satisfaction can contribute to other issues, though probably not cancer.
Mr. George Henschel, Department of Labor’s legal counsel for NACE, introduced a copy of Dr. Wegman’s prepared statement and cover sheet as Exhibit 1.
Presentation from the Guidelines Workgroup
Mr. Paul Fontana introduced the Guidelines Workgroup members, noting they also had support from Mr. Jim Maddox of OSHA. The goals set for the workgroup meeting on September 23, 2003, were to establish criteria for selecting industries for guideline recommendations and to advise on industries for which those guidelines would be recommended. The workgroup analyzed data from the Bureau of Labor Statistics (BLS) in order to identify industries with the largest number of people affected with MSDs, as well as industries with the highest incident rate of MSDs. The workgroup also considered looking at trend data.
The workgroup used the definition of MSDs that was included in the BLS data. After analyzing the data, the workgroup took a close look at the top 16 industries that had an incidence rate greater than 57.5. The workgroup included nursing homes, retail grocery, and poultry industries because guidelines have either already been prepared or are in the process of being prepared for these industries. The top six industries were nursing homes, trucking and courier services, air transport schedules, hospitals, groceries and grocery-related products and wholesale, and motor vehicles and equipment. The workgroup narrowed data further by ranking each industry and compiling a preliminary list of industries to target for guidelines: air transport, hospitals, trucking and courier, grocery wholesale, and motor vehicle.
Before making a formal recommendation for guidelines for these industries, the workgroup would like to see OSHA’s 5-year trend data on MSDs for all 19 industries to identify whether any significant progress has been made without guidelines. The workgroup has requested this information from OSHA.
Mr. Fontana also discussed the workgroup’s recommendation to drop the issue of task- or occupation-specific guidelines. In their previous meeting, the workgroup was adamant about task-specific guidelines, but after analyzing the industries and discussing how task-specific guidelines would be developed the workgroup agreed that they might be repetitive.
Future activities for the Guidelines workgroup include continued discussions on general guidelines, data or trends that will be reviewed prior to making any final recommendations, and continued discussion on guideline structure.
Mr. Goldsmith asked for clarification on the use of the BLS definition of MSDs. Mr. Thompson responded that the definition was used because the data used that definition and clarified that there was not an endorsement of the definition by NACE.
Mr. McCausland expanded on the data that was used by the workgroup. Jim Maddox at OSHA completed a search of the BLS data and pulled the pertinent information, which included two-, three-, and in some cases four-digit SIC code groupings of about 950 different industries or industry segments. The workgroup was provided with a table that included the number of meeting days and incidence of non-fatal occupational injuries and illnesses with days away from work involving MSDs (per the BLS definition) for 2001. The workgroup will also look at the recently released 2002 data.
Mr. Thompson added that the workgroup’s goal is to make recommendations on guidelines that impact the largest population, based on the largest number of injuries.
Dr. Audrey Nelson asked for clarification on the workgroup’s decision to focus on industry-specific areas instead of risk areas of specific occupations. Dr. Nelson expressed her concern that in the area of hospitals, taking a global approach and trying to place every high-risk job into one guideline would dilute the importance of specific emphasis areas that need to be addressed. She also noted that a guideline for nursing homes does not necessarily apply to acute care hospitals.
Mr. Thompson responded that the workgroup did have discussions about task-specific areas and is still having discussions on the best way to proceed. The workgroup attempted to answer the questions of what happens once an industry is chosen to have a guideline. One option is holding discussions with stakeholders as to which specific areas should be addressed.
Dr. Nelson reiterated her concern that the guidelines for industries that are very broad may dilute the impact of the guideline. Mr. Thompson agreed.
Mr. Koskan clarified the workgroup’s intent for the process that might take place once an industry is chosen. Once an industry is chosen, the next step may be for OSHA to work with stakeholders, trade associations, and define what specific area, in hospitals for example, seems to be the primary area of concern. The guideline would be developed for that area, not the entire industry.
Mr. Fontana added that the data the workgroup has been using has shown that hospitals employ more people than nearly any of the other groups and the incidence rate is second highest. Adding to Mr. Koskan’s thoughts, Mr. Fontana clarified that the industry should consider where it should to focus its attention. It should be the industry that comes together to determine where the problem is and what needs to take place.
Dr. Nelson commented that one slide of the workgroup’s presentation was misleading when it stated the group was ruling out specific occupations and risks. Instead it appears the workgroup is choosing specific industries and then may subdivide by occupation or risk at a later time.
Mr. Thompson clarified that the workgroup is not making a recommendation to have guidelines for specific tasks, such as material handling. Instead, they are looking at an industry and envisioning that all of its stakeholders will participate in the guideline process since they are the best qualified to direct guidelines toward tasks or operational efforts. Mr. Thompson added that Dr. Nelson has a valid point and the workgroup will be looking at subsets of the SIC codes to see if they are significant factors.
Dr. Nelson added that in the Veteran’s Administration, 80-90 percent of injuries in hospitals are in nursing, and she would want that reflected in any guideline that was developed.
Dr. Bernacki suggested that the workgroup consider tasks that, while incidence is low, numbers are very high, such as keyboarding. Mr. Thompson agreed it is something the workgroup will consider, with comments from the other committee members.
Ms. Brooks stated that SIC codes will be eliminated and the BLS will be using NAICS codes instead. This may have important implications for the future as the BLS has not committed to a cross-over study.
Mr. Goldsmith offered his mild dissent to Dr. Bernacki’s suggestion about studying keyboarding, stating that it has been studied already and the results have been inconclusive.
Dr. Bernacki agreed that it is difficult to examine keyboarding, particularly because the incidence is very low. However, his experience as a physician is that there are certain factors in keyboarding that increase the risk.
Mr. George LaPorte commented that in the last meeting there was a discussion about looking at the office worker situation, and an OSHA representative mentioned that there was some type of guidance already available. The workgroup will look into it and find out what document is available.
Ms. MaryAnn Garrahan, OSHA, replied that Mr. Henshaw had referenced an e-tool during his remarks.
Mr. Thompson repeated that prior to offering recommendations to the full committee, the workgroup would like to first look at the trend data that OSHA is compiling. For now, the workgroup is looking to the NACE committee to make sure they are heading in the right direction with the guideline work.
Dr. Richard Wyatt suggested that the workgroup consider ways to work with some of the alliances that OSHA has already established. The workgroup could consider working with OSHA and those alliances on a precursor to the guidelines. Mr. Koskan added that the workgroup has discussed working with alliances once the industries are narrowed down. Mr. Thompson responded that he would bring up the suggestion with the members of the workgroup.
Dr. Lida Orta-Anes added that the workgroup should consider establishing a format for the guidelines in order to make sure there is uniformity between multiple guidelines. Mr. Thompson responded that the workgroup has had discussions on the structure of the guidelines and is continuing to discuss the issue.
Presentation from the Outreach and Assistance Workgroup
Dr. Nelson was recognized as the discussion leader for the Outreach and Assistance Workgroup and noted that she would be co-presenting with Dr. Wyatt and Ms. Brooks. Dr. Nelson offered a brief overview of the topics discussed during the workgroup meeting and presented five recommendations, or action items, for the committee’s review:
Ms. Rivera commended the workgroup for their hard work and added that with regard to social marketing, the bottom line for business owners is cost. Speakers that are invited to the January meeting to talk about social marketing should address the issue of cost in order to address small business owners’ fear that implementing ergonomic practices will cost too much and put them out of business. Ms. Rivera suggested inviting someone from the Small Business Administration.
Dr. Nelson agreed that cost is a concern, explaining that this is why the workgroup separated the social marketing from the business case on ergonomics. Large businesses are also concerned with costs. Dr. Nelson asked the entire committee to suggest names of possible speakers for each issue.
Ms. Rivera added that it is easier for larger businesses to absorb the costs.
Dr. Bernacki suggested that the committee invite a speaker that can address both large and small business cases.
Chair Kerk asked the committee if there was consensus on the first three recommendations:
Dr. Nelson recapped the workgroup’s recommendation that NACE endorse the recommendation for enhancing the NACE Web site.
Mr. Koskan asked for clarification on the recommendations about the Web site enhancements and the success story templates.
Ms. Brooks acknowledged that the two are connected, but the Web site enhancements address usability whereas the success story templates are more specific to the content and process of collecting the success stories.
Dr. Bernacki asked about the expense of the Web site enhancements. Dr. Nelson responded that they do not have a dollar amount, but an OSHA representative was present at the meeting to help answer this question.
Ms. Elizabeth Sherfy, Office of Outreach Services and Alliances at OSHA, stated that she maintains the ergonomics outreach and assistance portion of the Web site and that most of the recommended changes can be made very quickly. The changes to the search engine will have to be discussed with the Directorate of Information Technology.
Chair Kerk asked the committee if there was consensus on the fourth recommendation to make enhancements to the OSHA Web site. The committee reached consensus.
Dr. Nelson recapped the recommendation to enhance the template and revise the process for collecting OSHA success stories. The workgroup plans to provide detailed information about the template and process in January.
Mr. McCausland asked the workgroup to consider the importance of keeping the templates simple enough that people will still be willing to take the time to complete them and not get discouraged.
Dr. Nelson agreed and added that the workgroup is trying to balance the ease of submitting the information with the usefulness of the information.
Mr. McCausland responded that it is already difficult enough to get success stories, and if the new template makes it still tougher, the committee will have defeated the purpose of them.
Chair Kerk asked the committee if there was consensus on the fifth recommendation to make enhancements to the success stories template and submission process. The committee reached consensus.
Chair Kerk asked the committee to endorse the sixth action item to move forward with working on the Early Adopter’s program. The committee reached consensus.
Mr. Fontana added that in terms of outreach, the committee should use venues other than OSHA’s Web site, such as industry trade journals. The Early Adopter’s program could be publicized in these industry journals.
Presentation from the Research Workgroup
Dr. Orta-Anes was recognized as the discussion leader for the Research Workgroup and began by reviewing its work plan, noting that the forum and the discussion with Dr. Hal Corwin are in progress. There was also a correction to the wording of the second page of the work plan.
The workgroup recommended that NACE endorse the idea of holding a symposium at the January 2004 meeting where experts will present information on known research gaps relating to critical research issues in ergonomics that will help move the science into the applied world. The purpose of the symposium would be to enhance the knowledge base of the NACE committee as it makes recommendations to OSHA on needed research areas. The suggested title of the symposium is “Musculoskeletal and Neurovascular Disorders—The State of the Research Regarding Workplace Etiology and Prevention.”
Dr. Orta-Anes reviewed the proposed abstract requirements, speaker requirements, and promotion methods, acknowledging that there is not a lot of time before the January meeting. There was also a discussion about the proposed format of the symposium, which would include a 1-day panel consisting of up to four 90-minute sessions. Each speaker would have 20 minutes to present, followed by 10 minutes of questions or discussion from the panel. Potential topics were also discussed, including the state of scientific research concerning the relationship between the workplace and MSDs, OSHA's definition and diagnosis, costs and work relatedness, exposure/response relationships, intervention studies, and study design, including research methodology. The two recommendations or action items from the Research Workgroup were:
Mr. Koskan asked whether the committee should narrow the focus of the call for papers to interventions and results as opposed to broader categories. Dr. Orta-Anes replied that the workgroup discussed narrowing the list of topics but decided to keep them general in order to attract the most submissions.
Mr. Fontana asked whether each of the four 90-minute presentations would cover a different subject matter. Dr. Orta-Anes replied that ideally they would, but it ultimately depends on the types of abstracts that are submitted.
Mr. Fontana asked whether a university would select the presenters. Dr. Orta-Anes responded that the workgroup is open to having a university sponsor the event. Otherwise the symposium would be held in a hotel in conjunction with the next NACE meeting. The workgroup recommended that Chair Kerk decide which abstracts should be recommended to OSHA for acceptance.
Mr. Fontana expressed his concern about the process becoming politicized. Researchers have agendas and it is important for NACE to make sure whomever is the selecting body does not let the process become too politicized. Dr. Orta-Anes agreed.
Mr. Fontana also expressed his concern about the short timeframe for planning this symposium. Dr. Nelson reiterated Mr. Fontana’s concern about the short timeframe. She suggested selecting people based on the priorities instead of offering a general call for papers.
Ms. Susan Sherman reminded the committee that the call for papers asks for abstracts of peer reviewer papers or proposals, so that no one will be creating original research to present.
Ms. Rivera noted that the January meeting is a time that has already been approved by OSHA. In addition, the workgroup would like to hold the symposium at the January meeting in order to allow time at the following two meetings in 2004 to sort through any final recommendations for OSHA.
Mr. Goldsmith suggested that the committee pre-select possible authors and speakers and contact them in advance of the call for papers in order to move the process along. The call for papers would still catch others that are interested in presenting.
Chair Kerk stated that if the committee endorses the recommendation of the workgroup, the committee members should offer names of potential speakers as soon as possible. Chair Kerk clarified the decision to issue the announcement in the Federal Register and also solicit submissions from specific people.
Ms. Brooks asked for clarification on who will be in the audience. Ms. Sherman responded that the meeting would be open to the public just as the NACE committee meetings are.
Mr. Fontana asked Tom Waters, NIOSH, how the symposium would differ from the national symposium held at Ohio State in 2003. Mr. Waters responded that the major difference is that NACE would be inviting people on differing sides of the same issue in order to get a back-and-forth discussion.
Mr. Fontana urged that the speakers be able to apply the science to the real world and not present research for research sake.
Dr. Kasdan expressed his opposition to the symposium stating that inviting speakers to present individually would be more appropriate.
Chair Kerk asked the committee for consensus on endorsing the plans to hold a symposium at the January meeting. The committee reached consensus.
Mr. Henschel, introduced the following exhibits into the record:
Chair Kerk proposed keeping the January NACE meeting to a 2-day meeting, which would still include one full day for the symposium. He announced the dates of future meetings, noting a possible change in the September 2004 meeting.
Mr. McCausland asked for clarification on the format of the symposium and whether each panel would cover a different theme. Chair Kerk responded that the plan is to cast a wide net and hopefully get back a diverse selection of topics and papers that would be grouped into four areas.Meeting #4: January 27-28, 2004, to include the full day symposium.
Dr. Orta-Anes agreed that the workgroup is hoping that the call for papers will attract a diverse group of submissions. She reiterated that it is very important for the committee to help in the solicitation of submission to insure the abstracts are on target.
Ms. Brooks stated that the committee should have a general consensus of what topics should be targeted.
Dr. Bernacki added that the topics that continue to emerge as areas needing future research are interventional studies and cost/benefit.
Mr. Koskan added that through this symposium the Guidelines Workgroup might be able to identify actions that work and can be applied in guidelines.
Mr. Goldsmith reiterated that the scope of the symposium should not be too narrow and that the committee should first see what kind of response it receives. Mr. Goldsmith also directed the committee again to the topics listed in the Federal Register notice.
Chair Kerk thanked the committee for their work and adjourned the meeting.