In this series of articles, OH.com asks leading ergonomic experts what they think about OSHA''s voluntary ergonomic guidelines and the course of action they''d like to see the agency take.
Kent Wilson: Many Questions Remain
Kent Wilson says he wasn''t surprised by OSHA''s decision to release voluntary guidelines for ergonomics, rather than a new standard. As the training manager for Ergodyne, a St. Paul, Minn., company that specializes in ergonomic products and services, Wilson has helped a number of companies, large and small, develop ergonomic programs that reduced the incidence of musculoskeletal disorders among workers. Wilson says that there are many gaps in OSHA''s plan that need to be filled in.
"How detailed, how specific - how task-specific and industry-specific - will OSHA make the guidelines?" questions Wilson. "How many industries will be targeted? Will there be industry-specific guidelines for construction, maritime, manufacturing, healthcare, office workers, other industries? Will there be conflicts because one company bleeds over into several industries?"
He says he''s not opposed to the idea of guidelines, noting the voluntary ergonomic guidelines developed for the meatpacking industry have had some success, and there''s no reason to believe that voluntary guidelines won''t work for all industries.
"Guidelines can be extremely useful, extremely beneficial" says Wilson. "The challenge is getting the ''bad players'' to participate."
He says the carrot and the stick scenario comes to mind: "Voluntary guidelines are the carrot, but you need the stick too," he points out.
And the stick - enforcement - is perhaps OSHA''s greatest challenge in Wilson''s opinion.
Under the guidelines, OSHA will cite companies for ergonomics violations under the General Duty clause, something it has not had much success with in the past. There is a two-fold reason, says Wilson, why citing under the General Duty clause is problematic: There is no single ergonomic solution which works for all companies, and OSHA inspectors do not have the training to determine if a company''s ergonomic solutions are effective.
"There is no one right answer," admits Wilson. "We know what''s good, better, best, but OSHA has a hard time putting numbers on it. If 100 repetitions are too many, then are 99 okay? No? Then how about 98?"
Although part of OSHA''s plan involves creating a national advisory committee to advise the agency on research gaps, Wilson claims, "It''s unlikely we''ll ever have definitive research with specific numbers because human beings are all different and it''s difficult to predict if someone''s going to develop a musculoskeletal disorder (MSD). Some people are extremely sensitive to any risk factors, others are iron men and nothing seems to hurt them."
Most employers are aware of those differences, adds Wilson, and match employees up to tasks based on strength and ability. "Sometimes employers don''t get it right, or they just don''t have enough people to fill some of those manual labor jobs and have to put people in who are not as suited to the job," says Wilson, "but day to day, most employers try to do the best they can with the information they have. They really want to do the best thing for their employees."
The problem, he adds, will be if OSHA inspectors don''t recognize the accommodations employers make for workers will vary from workplace to workplace, from employee to employee. OSHA inspectors, he says, will probably use checklists to determine if employers are doing the "right" things. Such checklists don''t have the flexibility to allow inspectors to make allowances for varying solutions, he says.
For example, Employer 1 might be doing A, B and C to reduce the risk of MSDs while Employer 2 in the same industry is doing X, Y and Z. Is Employer 2 wrong? No, says Wilson, if the outcome - elimination or reduction of MSDs - is the same. And the only way for OSHA inspectors to realize that many different solutions could have the same positive outcome is education.
"OSHA must be willing to recognize that its inspectors don''t have all the resources they need to evaluate ergonomic programs at this point," says Wilson. OSHA needs to encourage its inspectors to learn about the issues surrounding ergonomics and attend seminars and training, he adds.
"Sometimes OSHA gets it wrong. Sometimes the National Institute for Occupational Safety and Health gets it wrong. And that''s when it''s most damaging," Wilson insists. "Companies rely on them for guidance, and when they get it wrong, it has a huge impact."
by Sandy Smith ([email protected])