"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."
Why is OSHA pushing so hard to complete its ergonomics standard this year? I
want you to know that I've answered that question dozens of times since last
Of course, all of us gathered here today know the answer. Work-related
musculoskeletal disorders or MSDs are a serious, pervasive problem throughout
Every year 1.8 million U.S. workers experience work-related MSDs-back injuries,
carpal tunnel syndrome, or tendinitis, for example. This includes nearly 600,000
injuries serious enough to cause workers to miss work-a full third of the most
serious on-the-job injuries.
Here's another way to look at these numbers. Today, this day, more than 1,500
working Americans will suffer painful injuries related to overexertion or repetitive
motion. These injuries are potentially disabling and can require long recovery
periods. For example, workers need an average of 28 days to recuperate from
carpal tunnel syndrome-more time than necessary for amputations or fractures.
MSDs are also very costly injuries. Direct costs of MSDs total $15 to $20 billion per year. Indirect costs increase that total to $45 to $54 billion. That's an average of $135 million per day.
But real solutions exist that can spare workers pain and pare expenses for their
employers. It's time we began putting those solutions to work for everyone's
benefit. No worker should take a job to earn a living only to return home disabled.
And no employer should have to bear the expense associated with injuries that can
OSHA has found substantial evidence that ergonomics programs can cut workers'
compensation costs, increase productivity and decrease employee turnover. In
fact, as you know, ergonomics began as an effort to streamline work processes and
improve efficiency to save money.
In short, good ergonomics is good economics. It's about working smarter and
safer. That's good business.
We know better than to push equipment beyond its rated capacity. That's a
surefire recipe for malfunction or breakdown. So why would we want to push our
people beyond their physical capacity? Obviously, we don't.
OSHA has spent 10 years studying ergonomics, and the record includes more than
14,000 studies. During this rulemaking, we have received more than 8,000 public
comments and heard from more than 700 witnesses during our nine-week hearing.
The evidence is more than sufficient. It is overwhelming. Musculoskeletal
disorders are related to work, and reducing repetition, excessive force, awkward
postures and heavy lifting can reduce the risk of injury. The time to act is now.
In 1995, OSHA developed a draft ergonomics rule that it circulated for feedback.
That draft would have required employers to examine all jobs against a set of risk
factors. High-risk jobs would then need to be fixed.
The business community reacted swiftly and strongly. Business opposition led
Congress to pass appropriations riders for fiscal years 1995, 96 and 98, prohibiting
OSHA from even publishing an ergonomics proposal.
Business was up in arms at the prospect of having to examine every job in every
workplace to determine if doing that job might result in an MSD. Trade
associations and other business leaders wanted OSHA to find a better way to focus
the standard, to zero in on high-risk jobs.
So we developed a new proposal in 1999 to address this concern. It asks
employers with high-risk jobs-about 25 percent of general industry employers-to
provide information to workers and set up an injury reporting system. Employers
would only need to take action to analyze jobs when someone actually suffers an
Of course, using an injury trigger is not the most preventive approach. But it
zeroes in very effectively on jobs and activities where real problems clearly exist.
OSHA's proposal also recognizes that no ergonomics program will prevent every
MSD, and that different people may be affected by different risk levels. But the
injury trigger flags jobs that need correction to prevent future problems.
Witnesses in our hearings also pointed to the need to identify specific physical
risks that led to the injury and that must be reduced to avoid additional injuries.
We were encouraged to set thresholds for these risks would make it clearer to
employers when a job needs fixing and when they had done enough.
The state of Washington has used a risk factor approach in its new ergonomics
standard to help employers quickly determine which jobs require further analysis
and possible action. Under WISHA's standard, employers would need to examine
jobs that involve specific awkward postures, repetitive lifting of various weights or
engaging in other high risk activities for specified periods of time. The
Washington state standard requires worker education and reduction of physical
risks in individual jobs to reduce injuries.
WISHA expects a 40-percent reduction in work-related MSDs through its new
standard. This is based on research indicating that the lower the intensity, duration
and frequency of exposure to physical risk factors at work, the lower the risk a
worker will develop an MSD. Therefore, reducing the weight of objects workers
must lift, limiting the time workers must work in awkward postures or cutting the
number of repetitive motions workers must perform should reduce injuries.
Evidence presented in comments to us and at the OSHA hearing indicated this is a
One of OSHA's commitments in its 1999 proposal was to provide flexibility for
employers in determining how to solve problems. One size does not fit all. We
know it's critical in the final standard to maintain flexibility and continue a
At the same time, our proposal was criticized for being vague about when an
employer was in compliance. Employers want to know when they've done
enough. They want to be sure that their response is sufficient to protect their
employees. They want to be certain that their ergonomics program will meet the
approval of an OSHA inspector.
Finding the balance between performance and specification is very tough to do. If
we're not specific enough, we're not providing the guidance that some employers,
particularly small businesses, may need. If we're too specific, our requirements
won't give employers the flexibility they need to resolve the unique problems they
face. It's damned if you do, and damned if you don't. But if we must tilt one way
or the other, I think it's most important to maintain flexibility. And no doubt I'll
hear more on this subject from speakers who follow me.
Now I want to address Work Restriction Protection. This has proven to be one of
the more controversial provisions in OSHA's proposed ergonomics standard. It
has generated a significant amount of public comment and crossfire during the
hearing-even though earlier OSHA standards have required similar medical
removal protection. And in the case of high blood lead levels, workers may be
removed from jobs involving lead exposure for up to 18 months. We proposed a
six-month limit for WRP.
Under WRP, employees would receive full pay and benefits for light duty work
and 90 percent of net pay and benefits if they have to miss work. And WRP
payments are offset by any workers' compensation that injured workers receive.
The key to preventing serious disability as a result of MSDs lies in early reporting.
And more than any other OSHA standard, the ergonomics proposal depends upon
individual workers coming forward promptly to report their injuries.
OSHA's experience has shown that workers may be reluctant to report problems
early if doing so will cause them to miss work and lose pay. We must find a way
to reassure employees that they won't be penalized for reporting injuries. This is
particularly a problem for workers at smaller businesses, which often do not
provide sick time. Currently, if their employer directs them to take a few days off
to recover from tendinitis, workers who do so know their next paycheck will be
short. So, a worker may decide instead to put up with the pain in hopes that it will
just go away.
In our final standard, we need to include some strategy that encourages early
reporting to reduce both the incidence and severity of MSDs. When we depend so
heavily on workers to report problems, we must find a way to encourage them to
do it sooner rather than later, before irreversible damage occurs.
And we are close to a final standard. I expect that our final standard will be
published by the end of the year. After that, our challenge will be to provide
employers with the assistance they need to implement programs that fit their
What we must remember is that real solutions are available to fix problem jobs.
And when we identify them, both employers and employees will benefit.
While ergonomics relies on a scientific approach to fit the job to the worker, it
isn't necessarily exact. Sometimes it requires experimentation. But every safety
and health professional can identify solutions that eliminate musculoskeletal
disorders that result from a mismatch between the job and the worker.
Solutions can be simple, obvious and inexpensive. Things like adding a platform
to reduce reach, padding hand tools and work surfaces, substituting a more
effective tool or reducing the size of items workers must lift. These are sensible
approaches that reduce risk without reinventing the factory. Often they are
suggested and developed by the workers in the jobs that need to be fixed.
While we have sound science linking work and MSDs, there is clearly room for
more research. The research work that panelists here are doing is important.
You've focused on an issue that is in the forefront of safety and health. And your
research has the potential to significantly improve lives.
How can we design the work environment and the work flow to minimize physical
stress? How can we re-design common jobs that have already resulted in injury?
How can we address ergonomics in other industries like construction? What
solutions are in use in Europe or Japan?
Are there more objective measures of MSDs that we could rely on? What
strategies prove most effective in treating various MSDs? What new interventions
might be successful?
We need your contributions, and we welcome them. We want to send every
worker home whole and healthy every day. Your work will guide employers and
employees in finding practical solutions to common problems to prevent injuries.
We appreciate your partnership in creating safer workplaces, and we look forward
to working together in the future.