The American Association of Occupational Health Nurses (AAOHN) is fully supportive of a regulatory strategy to address work-related musculoskeletal disorders.
However, AAOHN has concerns with the agency''s failure to incorporate many of the association''s recommendations for the final standard.
AAAOHN joins many other industry associations who are supportive of the standard yet still concerned by some of its elements.
AAOHN said it fears that many workers will remain unprotected by this standard. Industries that experience high rates of MSDs, such as the construction industry, are not covered under the current rulemaking.
The association said it is disappointed that OSHA has chosen to promulgate a standard that fails to adopt a preventative approach to addressing MSDs injuries.
"Waiting until an employee experiences an MSD simply goes against all theories of prevention," said AAOHN.
The association is also seriously concerned that the final rule does not require consultation of a health care provider to determine whether an "MSD incident" has occurred.
"Employers who do not have access to the knowledge, experience and training of a health care professional are not qualified to make determinations about whether an MSD has occurred or whether it is work-related," said AAOHN.
AAOHN noted that it remains concerned about the work restriction protections included in the final rule and whether they will withstand a legal challenge.
However, despite it''s concern, AAOHN said there are a number of positive aspects to the proposal:
- The standard is written in a manner that is relatively easy to understand.
- AAOHN is pleased to see that OSHA has continued to use broad language in defining health care professionals under the standard.
- It is also pleased to see the use of tools designed to assist employers in determining what is required of them by the standard. Tools such as the flow chart, job analysis tools, appendices and the basic screening tool will be helpful for employers to use when complying with the standard.
by Virginia Sutcliffe