In its comments filed last week to OSHA on the agency's proposed ergonomics standard, the American Society of Safety Engineers (ASSE) said a standard is needed, but outlined several concerns with the proposal.
Sparked by the possibility that the current negative debates being waged countrywide on the issue could result in total rejection of a standard, ASSE provided a counterproposal in its comments.
Based on input from its 33,000 members, ASSE believes its counterproposal offers a more reasonable and user-friendly approach to the control of workplace muscloskeletal disorders (MSD) and ergonomic exposures than the current OSHA proposal.
"This proposed standard can be of significant benefit to employees, employers, professional safety and health organizations, and the country overall if and when it is finalized," said ASSE President Frank Perry in a letter to OSHA.
"ASSE will continue to support OSHA in the creation of a feasible ergonomic standard, based on good science and sound technology, which will benefit all stakeholders, however, we urge OSHA to consider our counterproposal in an effort to assure that an effective standard is adopted."
Perry cited the fact that many of ASSE's members, who work for all types of industries, have developed and implemented ergonomic safety programs that have led to significant decreases in the number of workplace MSDs.
"In light of this fact and others, we believe that OSHA should consider a more incremental approach to the ergonomics issue and promulgating a standard," said Perry.
Perry suggested the agency could promulgate a regulation addressing lifting and back injuries followed by other workplace MSD standards and regulations.
In its proposal, ASSE suggests that OSHA consider utilizing the Meat Packing Guidelines as a basic approach that can later be strengthened when the agency obtains more scientific and technical data on effective workplace MSD intervention controls.
ASSE is also urging OSHA to develop a more reasonable standard which enhances occupational safety and health, and leave the issue of payment for rehabilitation, social issues and workers' compensation reengineering to the existing federal and state laws and regulations governing these areas.
ASSE believes that the 'one case' trigger called for in the standard is poor policy because many ergonomic problems arise off-the-job and in the absence of a clear triggering incident.
"Getting at the root cause is extremely problematic. If the cause is not in the workplace, trying to fix the workplace will not reduce or eliminate injuries," said Perry.
Perry noted that OSHA's proposal, as written, is cumbersome, confusing and unclear because it does not adequately explain what the standard actually requires for 1) a workplace ergonomic program, 2) the standard of proof to establish the program, and 3) how the workers restriction/payment portions of the standard will do anything to prevent workplace MSDs.
The proposal, Perry said, also needs to better focus on overall safety and health issues and not shift the focus to compliance with ergonomics.
"We believe it would be poor policy to allow ergonomics to become the primary driver of a safety and health program," said Perry.
In its comments, ASSE urges OSHA to promulgate this as a safety standard, not as a health standard as they are proposing to do.
"We believe that ergonomic injuries should not be treated in a different manner than other workplace injuries."
ASSE's comments on the proposal and a copy of its counterproposal are posted at www.asse.org