The OSHA draft provides good information on injury risk factors and job-specific workstations or areas, as well as good examples of employee involvement and successful ergonomic solutions in the field, the association commented. However, AIHA does make several recommendations intended to enhance the effectiveness of the guidelines:
AIHA encourages OSHA to add language to the guidelines to make it clear that if employers completely ignore the guidelines and have unacceptably high MSD rates, enforcement efforts can be applied under the General Duty Clause of the Occupational Health and Safety Act of 1970.
AIHA commented the guidelines should provide more extensive examples of practical ergonomics information, assessment tools and control strategies, with more specific definitions and design parameters.
AIHA suggests providing more details of effective ergonomics programs not to imply that all ergonomics programs must be set up in the same way, but instead to show employers a variety of methods or tools to establish an effective ergonomics program. Employers could review this information and decide what types of processes or programs, if any, would work at their facilities.
Risks specific to deli and dairy departments, present at many retail grocery stores, llare not included in the guidelines. These areas have unique concerns and should be addressed.
The guidelines' recommended postures and work zones are only as good as the design of each job and work area. AIHA encourages OSHA to organize these guidelines around the traditional hierarchy of controls, which emphasizes engineering controls over worker training.
