OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.
April 18, 1990
Dr. Richard R. Cornwall Professor of Economics Middlebury College Middlebury, Vermont 05753
Dear Dr. Cornwall:
Thank you for your letter of February 21 regarding occupational injury statistics relating to cumulative trauma disorders. As Dr. Fine rightly indicated, I--and many others in OSHA--share your interest in this topic.
You asked about possible sources of additional information on these injuries. Frankly, I have not done research in this area, and have no unique sources which might be of use. Some potential sources do exist, however, and an ERC could be a prime mover in bringing them into reality. For example:
-- Unions may have worker employment, injury and health care records which could be developed into data bases, exercising appropriate precautions to preserve the privacy rights of individuals.
-- The Communications Workers of America are involved in some studies involving ergonomic injuries and hazards. Data requirements could be addresses at the design stage of these projects. David LaGrande of the Communications workers might be helpful in this regard. His telephone number is (703)728-2483.
-- Steven Hantler of Chrysler Motors is implementing an ergonomics program in several assembly plants, and may have useable baseline statistics. His telephone number is (313)956-2177.
-- Similarly, Roger Loeffelbein, Vice President for Human Resources, Sara Lee Meat Group is also overseeing the implementation of a program in about 30 plants. He has expressed interest in broader applications of Sara Lee's work. His telephone number is 901-756-4051.
-- The National Council of Workers' Compensation Carriers might also be willing to cooperate in developing a data base, or in sharing information their members already have. Unfortunately, I do not have a contact person for that organization.
-- Within OSHA, you may find it useful to talk with Hugh Conway, who directs our regulatory analysis staff. He may well be aware of data sources which could fit your needs. His telephone number is 202-523-9690.
-- While a general solution to your data needs may be lacking, it might be possible to get several employers to pool information--through NIOSH or the ERC--for research purposed. Confidentiality of data could be preserved in this way, since NIOSH's research efforts are not directly linked to OSHA enforcement.
-- Firms which have entered corporate-wide agreements with OSHA might be approached with this in mind. Also, the American Meat Institute has expressed willingness to coordinate among its members and to stimulate cooperation for research purposes. You should contact Deven Scott on 703-841-2400 to discuss these possibilities.
I wish you well in this undertaking; if I may be of assistance in any way, please let me know.
Raymond E. Donnelly, Director Office of General Industry Compliance Assistance