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 9, 2014

Ms. Sudharma Jayatilake
12347 Wolff Dr.
Broomfield, Colorado 80020

Dear Ms. Jayatilake:

Thank you for your December 17, 2013 letter to the Occupational Safety and Health Administration (OSHA). Your letter has been referred to the Directorate of Enforcement Programs for an answer to your specific question regarding back- to- work tests that require lifting and carrying 50 pounds. A member of my staff contacted you by phone after we received your letter to discuss your question. This response constitutes OSHA's interpretation only of the question discussed and may not be applicable to any situation not delineated within your original correspondence. Your paraphrased scenario and question are below, followed by our response.

Scenario: Your employer required you to successfully lift and carry at least 50 pounds as a condition of your return to work as a nurse in the baby unit of the hospital.

Question: Is it an OSHA requirement for a nurse to be able to lift a certain amount of weight?

Response: OSHA does not have any requirement on how much an employee should be able to lift or carry. It does not interfere with the employer’s establishment of return- to -work tests involving lifting and carrying. The National Institute for Occupational Safety and Health (NIOSH) has developed an equation for guidance on assessing work conditions that include lifting. The NIOSH equation is widely used to determine a weight that would be safe for most employees to lift. The equation is described in the Application Manual for the Revised NIOSH Lifting Equation, which can be found on the NIOSH website, http://www.cdc.gov/niosh/docs/94-110/. The NIOSH equation is only a voluntary guideline.

Lifting assessments using the NIOSH equation have been simplified with tools developed by several states. The Ohio Bureau of Workers’ Compensation has a calculator for assessing risk levels associated with lifting various weights, which is available at

https://www.bwc.ohio.gov/downloads/blankpdf/LiftGuideBackStudy.pdf. Similarly, the Washington State Department of Labor and Industries has developed a calculator for analyzing lifting tasks, based on the NIOSH lift equation, and is available at http://lni.wa.gov/wisha/ergo/evaltools/ergocalc.pdf.

Using the NIOSH equation to assess patient handling, 35 pounds has been recommended as an upper limit for manual patient transfers (Waters, T.R.). When is it safe to manually lift a patient? American Journal of Nursing, 2007, 107(8), 53-58. This article stated,

“In general, the revised equation yields a recommended 35-lb. maximum weight limit for use in patient-handling tasks.”

If you would like more information on lifting and associated hazards, both OSHA and NIOSH have information on their respective websites, which can be found at:

OSHA: www.osha.gov/SLTC/ergonomics/index.html

NIOSH: www.cdc.gov/niosh/docs/2007-131/pdfs/2007-131.pdf

Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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 scenario and question 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 https://www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.

Sincerely,

Thomas Galassi, Director
Directorate of Enforcement Programs