"This document was published prior to the publication of OSHA's final rule on Ergonomics Program (29 CFR 1910.900, November 14, 2000), and therefore does not necessarily address or reflect the provisions set forth in the final standard."
ASSISTANT SECRETARY FOR OCCUPATIONAL SAFETY AND HEALTH
U.S. DEPARTMENT OF LABOR
THE SUBCOMMITTEE ON EMPLOYMENT, SAFETY AND TRAINING
SENATE HEALTH, EDUCATION, LABOR AND PENSIONS COMMITTEE
JULY 13, 2000
Mr. Chairman, members of the Subcommittee, thank you for inviting me to testify about the Occupational Safety and Health Administration's (OSHA) proposed ergonomics program and its possible impact on Medicaid, Medicare, and other health care costs.
Work-related musculoskeletal disorders (MSDs) are the most widespread occupational health hazard facing our Nation today. Nearly two million workers suffer work-related musculoskeletal disorders every year and about 600,000 lose time from work as a result. Although the median number of lost workdays associated with these incidents is seven days, the most severe injuries can put people out of work for months and even permanently disable them. The direct costs attributable to MSDs total $15 to $18 billion per year, with indirect costs (such as resulting management costs or the cost of production losses) increasing the costs to employers to more than $45 billion.
In the health care sector, the Bureau of Labor Statistics reports that there were nearly 90,000 MSDs resulting in days away from work in 1998. Almost fifteen percent of MSDs in private industry occurred in the health care sector -- largely in hospitals and nursing homes, and often due to lifting and moving patients. In addition, witnesses at OSHA's public hearings representing employees in sonography testified that as many as 75% of technicians doing ultrasound suffer from MSDs. OSHA estimates that workers' compensation for MSDs in the health sector cost $2.8 billion in 1996, with total indirect costs estimated to be about $5.8 billion.
The human dimension of this problem in the health care industry is striking. Women, in particular, experience a high number of MSDs, because a large number of women work in health care jobs - nurses, nurses aides, orderlies, and attendants - associated with heavy lifting or awkward postures.
For example, Beth Picknick, a registered nurse working in an ICU unit, suffered a career-ending back injury that was devastating, both personally and professionally. Throughout her career, Ms. Picknick helped patients move from their beds to chairs and back. Twisting, bending, pulling and pushing were all part of the job. She never had any back problems. While helping to move a patient, Ms. Picknick severely injured her back. Physicians, surgeons and physical therapists were not able to relieve the constant pain. Finally, two years after the injury, Ms. Picknick had spinal fusion surgery coupled with a major rehabilitation program. She was willing to endure whatever pain it took to return to the job she loved. Despite the surgery and the physical therapy, however, she cannot return to her job. Nor can she participate with her family in bicycling, racquetball, waterskiing or the yearly white water rafting trips she used to enjoy.
Similarly, another nurse at another workplace developed carpal tunnel syndrome in both wrists due to manually cranking beds and pushing tables and shower chairs with bad castors. Sometimes she cannot feed herself. She is on complete disability and awaiting four surgeries, one on each wrist and one on each shoulder. She says that if the health care facility had had proper equipment, this might not have happened. Workers like these are why it is important for OSHA to issue its ergonomics regulation.
Ergonomics has its roots in improving efficiency and productivity. For years, many employers have known that good ergonomics is often good economics. And those employers have not only saved their workers from injury and potential misery, but they have saved millions of dollars in the process. OSHA has spent 10 years studying this issue, analyzing evidence, reviewing data, talking to stakeholders, and discussing ideas and options. It is now time to act.
OSHA's proposed ergonomics program standard draws on the experience of companies that have implemented successful programs. The proposed standard relies on a practical, flexible approach that reflects health care industry best practices and focuses on jobs where work-related MSDs occur, problems are severe, and solutions are generally understood. It would require health care industry employers to address ergonomics for manual handling jobs, where we know the problems are most severe. In other jobs, it would require health care employers to act when employees report work-related MSDs.
Opponents of OSHA's proposed rule say it would have an adverse effect by increasing the costs of services for patients who depend on Medicare and Medicaid. To the contrary, I believe the benefits of ergonomics programs will greatly exceed the costs, which will be comparatively small in the context of total Medicare and Medicaid expenditures. Any potential costs will be more than offset for the health care sector because the benefits of the standard will likely far outweigh the costs. An ergonomics program standard can help hospitals and nursing homes reduce Medicare and Medicaid expenses by improving the productivity of health care workers through the reduction of costly injuries to staff. For example, a standard portable device for lifting patients can be purchased for $3,000. The average cost of back surgery, according to Health Care Financing Administration (HCFA) data is $16,072. And this figure does not include indemnity payments for the injured worker's lost time or replacement costs. In any case, OSHA estimates that the potential costs of the ergonomics program standard to the health care sector in 1996 would have been $644 million (in 1996 dollars) -- less than 0.2 percent of Medicare and Medicaid costs in that year. These costs would not significantly contribute to growth in Medicaid and Medicare costs. The annual costs of OSHA's proposed ergonomics program to the health care sector -- even assuming no benefits from the standard -- represent less than one percent of the projected increase in Medicare and Medicaid costs from 2000 to 2005.
OSHA believes there is substantial evidence to show that ergonomics programs can save workers' compensation costs, increase productivity, and decrease employee turnover. MSDs are preventable, and there are innumerable examples of health care employers who have succeeded in finding different ways to protect their workers from sometimes disabling injuries. In one study, a nursing home reduced lost workdays from back injuries by 50 percent after implementing a comprehensive ergonomics program. Another nursing home reduced lost workdays by 89 percent after its employees began using patient-lifting devices. One hospital reduced back injuries by 94 percent and significantly improved nursing productivity by having a trained-lift team perform 95% of all patient lifts. These types of ergonomic solutions in the health care industry are not new, nor are they limited to the United States. The United Kingdom has implemented a general policy of eliminating hazardous manual lifting of patients except in life-threatening situations.
I have attached to my testimony a chart that lists dozens of health care providers across the United States who have implemented successful ergonomics programs. In the State of Maine, hospitals and nursing homes as well as home health care providers have reduced MSDs and related costs by implementing ergonomics programs. For example, the Kennebec Health System of Augusta, Maine, reduced annual lost workdays from 1,097 to 48 after it implemented an ergonomics program and began using lift-assist devices. As a result, their insurance premium fell from $1.6 million annually to $770,293 - a cost savings of more than $800,000. Another health care system, Sisters of Charity Health System in Lewiston, Maine, reduced its workers' compensation costs for work-related MSDs by about 30 percent between 1994 and 1996 after introducing and implementing patient-lifting equipment. A nursing home, St. Joseph's Manor Inc. of Portland, Maine, reduced their total occupational injuries and illnesses by 40 percent after implementing an ergonomics and safe-lifting program. And home health care providers such as Androscoggin Home Health Services in Lewiston, Maine, cut their workers' compensation costs by 50 percent after emphasizing safe-lifting techniques and back biomechanics.
The successful ergonomics programs and experiences of these health care providers are not an isolated occurrence, according to the hearing testimony of Mr. Carl Siegfried, of Maine Employers Mutual Insurance Company (MEMIC), the state's largest provider of workers' compensation insurance. Mr. Siegfried testified at the hearing on the proposed ergonomics rule that his insurance company represents all kinds of health care providers. None of the providers they insure have found ergonomics programs and controls to be unsuccessful or infeasible and none have been driven out of business. Moreover, Guy Fragala, Director of Environmental Health and Safety at the University of Massachusetts Medical School, testified that a study done by MEMIC "demonstrated a drop in medical and indemnity costs from lifting injuries from $75,000 in 1993 to less than $5,600 in 1997." This drop followed the implementation of an Ergonomic Management Program with a "no manual lift" policy as the program's cornerstone.
The success of ergonomics programs and controls is not limited to Maine providers. I would like to highlight a few more of the success stories here:
- University Nursing Center of Enid, Oklahoma cut the rate of work-related MSDs by 75 percent from 1996 to 1998 and reduced lost workdays by more than 85 percent through its ergonomics program.
- In just two years, an ergonomics program at Lovely Hill Nursing Home in Pawling, New York, led to a 75 percent decline in the lost-time injury and illness rate and a reduction in days lost to MSDs from 287 to 37.
- Between 1995 and 1997, Hallmark Nursing Centre in Troy, New York, lowered their annual rate of total lost-time injuries and illnesses from 23.5 to 9 after implementing an ergonomics program.
- Between 1994 and 1998, after putting into place a safety and health program and an ergonomics program, ergonomic-related back injuries at Citizens Memorial Hospital in Bolivar, Missouri, decreased from 20 to 3. Citizens estimates that it has saved $300,000 per year as a result.
- From 1995 to 1997, Delmar Gardens North, a Florissant, Missouri, nursing care facility, implemented an ergonomics program and reduced by 50 percent the rate of back injuries among its staff nurses aides and the lost workday rate associated with those injuries.
- North Village Park, a nursing care facility in Moberly, Missouri, bought new lifting equipment and reduced the number of lost work days from 473 in 1995 to 16 in 1997.
- Sunnyrest Health Care Facility in Colorado Springs, Colorado, reduced their rate of workplace lost-time injuries by 75 percent between 1996 and 1998 after improving their ergonomics program by adding patient-lifting assists to reduce the risk of injury associated with resident transfer.
- After putting an emphasis on their ergonomic-lifting safety program, Laurel Center in Harrisburg, Pennsylvania, reduced their rate of ergonomic-related back injuries by more than two-thirds in 1999.
These successful programs show that ergonomics programs like those to be implemented by employers under OSHA's proposal often reduce costs rather than increase them. Many employers with successful ergonomics programs have included the same basic elements in their programs that you will find in our proposal: They look at the jobs where employees are getting hurt or reporting pain. Where they find a problem, they fix the jobs in a way that is appropriate to their workplace. Knowing that early intervention saves money and preserves health, they make sure their employees receive early and effective medical management and pay attention to recommendations for light duty or other measures. They train employees on how to use patient-lifting devices and other good patient transfer procedures. Finally, they evaluate their ergonomics programs to see what is working and what may still need improvement.
Some commentors also have expressed concern about the proposed standard's potential effects on the rights of patients and nursing home residents. A number of nurses and nurses aides testified at the OSHA ergonomics hearings that most patients welcome the use of patient-lifting devices because it makes them feel more secure and reduces their fear of falling or being dropped. These workers also told OSHA about patients suffering skin tears, broken hips, and shoulder dislocations when there are slips or falls during manual lifting procedures. One nurses aide noted that occasionally patients have been reluctant to use lifts, but that after someone speaks with them and demonstrates the enhanced safety that is provided for them and for staff, the patients prefer the lift. Hospitals and nursing homes that use patient-lifting devices have found them safer and more secure for patients and have found that few, if any, patients refuse them. In any case, while the employment of patient-lifting devices is very effective in reducing ergonomics hazards, there are other means of complying with the proposed standard, such as trained manual lifting teams. I can assure you that OSHA will work with employers to ensure that patients' rights are respected. OSHA will not issue citations where a patient refuses the use of a mechanical lift and the employer provides other means of complying with the standard.
Since March, we have held nine weeks of public hearings across the country in Washington, D.C., Chicago, Portland, Oregon, and Atlanta. We've heard from more than 1,000 witnesses, and we've received more than 7,000 public comments -- many from the medical community -- on our proposed standard. We are continuing to evaluate all that we've heard and all that we've read. But to my knowledge, the evidence is overwhelming: Ergonomics is good business in the health care industry, just as it is in the rest of general industry.
Mr. Chairman, thank you for this opportunity to provide the Subcommittee with information on OSHA's ergonomics proposal. I will be happy to respond to any questions.
|California||Vale Health Care Center||70||Reduced the number of back injuries from 10 per year to 1.|
|Colorado||Centura Health||130||By strengthening their ergonomics program in 1996, this employer cut their rate of related lost time injuries in half in 1997.|
|Colorado||Community Care of America||70||Community Care implemented an ergonomics program in 1996 and was able in the first year to achieve a 50% reduction in their rate of associated workplace injuries.|
|Colorado||Rose Health Care||Not available||Cases receiving immediate intervention showed a reduction in compensation costs.|
|Colorado||Sunnyrest Sanitorium Dba Sunnyrest Health Care Facility||121||By beginning to improve their ergonomics program in 1996 and continuing to do so, this health care facility was able in two years to reduce their rate of workplace lost time injuries by 75% and the lost work days associated with them by two-thirds.|
|Connecticut||Hospital of Saint Raphael||Not available||Lost work days resulting from patient transfer injuries dropped 15.9 to 13.1 days in 6 months.|
|Florida||Bayside Manor||130||Compared with 1997 rates, Bayside Manor in 1998 cut their incidences of total lost time injuries and back injuries by over 50%. The severity of those injuries was also greatly reduced.|
|Florida||Cypress Rehabilitation and Healthcare Center||125||After aggressively training their staff on proper lifting techniques in 1997, this employer's incidence of related back injuries and upper extremity musculoskeletal disorders in 1998 was reduced by 80%. The severity of those injuries that did occur, as reflected in the number of lost working days associated with them, was also down significantly.|
|Georgia||Dogwood Health & Rehabilitation||66||While it was already half way through 1997 when Dogwood strengthened their ergonomics program, their rate of lost time injuries and the number of associated lost work days were both still down by 50% for the year, compared to 1996 levels.|
|Georgia||NHC Healthcare-Rossville||109||After implementing an ergonomics program in 1997, this small health care facility achieved a 50% reduction in their related injury experience.|
|Illinois||Sunny Hill Nursing Home||300 beds||After suffering a rash of overexertion injuries, they established an ergonomics program and an immediate significant drop in injuries.|
|Maine||Androscoggin Home Health Services||520||Between 1992 and 1996 this home health care provider's ergonomics program emphasizing safe lifting techniques and back biomechanics cut their workers' compensation costs by 50%.|
|Maine||Kennebec Long Term Care||250||Implementation of an ergonomics program aimed at patient transfer in a nursing home has reduced associated back injuries by 80% and lost workdays by more than 90%.|
|Maine||St Joseph's Manor Inc.||270||Three years after being invited to join the Maine 200 Pilot Program this nursing care employer's ergonomics and safe lifting program had reduced their total occupational injuries and illnesses by 40%.|
|Maine||Sisters of Charity Health System||780||In an industry with one of the highest incidence rates, SOCHS achieved a 35% reduction in workers' compensation costs for WMSDs over two years.|
|Missouri||Citizens Memorial Health Care Facility||110||Ergonomic injury incidence and severity rates were reduced more than 50%; 100,000 in direct cost savings were realized.|
|Missouri||Delmar Gardens North||170||From 1995 to 1997, the ongoing implementation of this nursing care facility's ergonomics program resulted in a 50% reduction in both the rate of back injuries incurred by its staff nurse aides and the lost work day rate associated with those injuries.|
|Missouri||North Village Park LLC||158||By strengthening their ergonomics program in 1996, this nursing care facility reduced their rate of related occupational injuries from 1995 to 1997 by more than 75%, and cut the number of lost work days associated with those injuries from 473 in 1995 to 16 in 1997.|
|New Mexico||Presbyterian Health Care Services||Not available||Reduced rate of work-related back injuries.|
|New York||Lovely Hill Nursing Home||90||The ergonomics program in place at this nursing care facility reduced the overall lost time injury and illness rate by 75% between 1996 and 1998. Lost time back injuries and upper extremity musculoskeletal disorders declined from 9 to 2 cases in the same period, and the number of lost work days associated with them went from 287 to 37.|
|New York||Hallmark Nursing Centre||78||Between 1995 and 1997 the Hallmark ergonomics program lowered their rate of total lost time injuries and illness rate from 23.5 to 9.0. Over this same time interval their number of lost time back injuries and upper extremity musculoskeletal disorders declined from 10 to 5 cases and the number of lost work days associated with them went from 423 to 185.|
|New York||Eden Park Nursing Home||82||The ergonomics program implemented by Eden Park reduced the total number of lost time back injuries and upper extremity disorders from 7 in 1996 to 2 in 1997 and in 1998. The number of lost work-days associated with these cases went from 170 to 124 to 44 in the same time period.|
|New York||Hornell Gardens Nursing Home||133||Since strengthening their ergonomics program in 1996, this mid-sized health care facility has seen their overall lost time injury and illness rate, as well as their lost time back injury rate decreased by over a third. The lost time associated with these back injuries was cut by over 50%.|
|New York||Iroquois Nursing Home Inc.||184||The ergonomics program at this mid-sized nursing care facility reduced the rate of total lost time injuries and illnesses, and the number of back injuries and upper extremity musculoskeletal disorders by approximately 50% between 1996 and 1998.|
|New York||Lakeside Nursing Home Inc.||300||After strengthening their ergonomics program at the start of 1997, Lakeside experienced a decline in their overall lost time occupational injury and illness rate of more than a third, and the lost time associated with these incidents was reduced by more than 50%.|
|New York||Margaretville Nursing Home||115||After implementing an ergonomics program in 1996 Margaretville had a 95% decrease in lost work days associated with ergonomic related injuries. As of May of 1998, they had experienced only one recordable back injury with one day of lost work.|
|New York||The Meadows and Westfall Inc.||201||The ergonomics program at this mid-sized nursing care facility reduced the rate of total lost time injuries and illnesses, and the number of back injuries and upper extremity musculoskeletal disorders by 40% between 1996 and 1998.|
|New York||Saint Francis Home of Williamsville||195||In the first year following initiation of their ergonomic program, their lost workday injury incidence rate was cut in half.|
|Oklahoma||University Nursing Center||77||In 1997 and 1998 the practical ergonomics program stressing safe mechanical lifting techniques at this small nursing care facility, cut the rate of related workplace injuries by almost 75% from what they were in 1996, and reduced the number of associated lost work days by over 85%.|
|Oklahoma||Infinity Care Systems Inc.||98||This small employer in an industry with a recognized high risk of ergonomic-related musculoskeletal injuries has managed since it opened in 1996 to achieve a remarkably low rate of such injuries and to practically eliminate any associated lost work-days. They credit their ergonomics program, which emphasizes bio-mechanics.|
|Oklahoma||Jan Francis Care Center LLC||104||From 1996 to 1998 the applied ergonomics program in place at this small establishment cut the number of ergonomic-related injuries and the lost work days associated with them by 80%.|
|Oklahoma||Mariner Health of Bethany||160||This employer credits OSHA's CCP program with giving them the kick start to become proactive with respect to worker safety. Since 1996 their practical ergonomics program addressing resident lifting hazards has cut their rate of related injuries by two thirds, and the rate of lost work days associated with those injuries by more than half.|
|Pennsylvania||Brevillier Village (Ball Pavilion)||160||Implementation of a patient lifting ergonomics program has reduced work-related injuries workers' compensation costs by 90%.|
|Pennsylvania||Church of the Brethren Home||190||Work-related injuries declined by 68 percent.|
|Pennsylvania||Laurel Center||233||After undergoing a recent management change and putting new emphasis on their ergonomic lifting safety program, this mid-sized healthcare facility reduced their rate of ergonomics-related back injuries by more than two thirds in 1999 and almost eliminated their upper extremity musculoskeletal disorders.|
|Pennsylvania||York Hospital||3,600||In 1994, back injuries dropped by 43%, the lost work day rate declined 55% and workers' compensation costs decreased 43%.|
|Texas||IHS of Texoma at Sherman||156||Since instituting their ergonomics program early in 1997, this small nursing care facility over the next two years cut their number of ergonomics-related injuries by two thirds, and reduced the number of lost work days associated with them by over 85%.|
|Texas||Mulberry Manor||88||By instituting an ergonomics program in 1997 this small nursing care facility was able to cut their rate of ergonomics-related injuries in half in each of the succeeding two years and cut the associated lost work days by more than 90%.|
|Texas||WestSide Campus of Care||125||After instituting an ergonomics program, this small nursing care facility cut their incidence of repetitive trauma-related musculoskeletal injuries by 75% and the number of associated lost work days by 85% between 1996 and 1998.|
|Wisconsin||West Allis Health Care||90||In 1997 this small nursing care facility instituted an ergonomics program focused on back injury prevention that significantly reduced their incidences of cumulative trauma related injuries and sharply reduced the severity of those that did occur, based on the numbers of lost and restricted work days associated with them. In particular, severity measures were down more than 90%.|
|Wisconsin||Lincoln Lutheran Convalescent Center||144||In the first year following the implementation of an ergonomics program in 1996, Lincoln Lutheran reduced their ergonomics-related lost time injuries by two-thirds and the lost days associated with them from 748 to 111.|