Occupational Physicians Comment on Proposed Ergonomics Standard

The American College of Occupational and Enviornmental Medicine supports the premise of an ergonomics standard, but offers a number of recommendations and changes to OSHA's proposal.

The American College of Occupational and Environmental Medicine (ACOEM) said it recognizes the problem of musculoskeletal disorders (MSD) in the workplace and supports the premise of an ergonomics standard.

However, in its written comments to OSHA, ACOEM presented a number of recommendations and changes to the agency's proposed standard.

ACOEM said it encourages OSHA to adopt an ergonomics program that is limited to those disorders for which credible scientific evidence exists and where detection and elimination of hazards will result in a reduction in the number of disorders.

"OSHA should take into consideration that MSDs represent a heterogeneous group of conditions," ACOEM said in its comments. "Since it can be difficult to determine if an MSD is related to an individual's job duties, ACOEM urges OSHA to limit the focus of the rule to work-related MSDs -- only those that are directly related to physical activities performed at work."

OSHA's proposed standard requires that the employer be responsible for determining if an illness or injury is the result of job duties.

However, since the triggers in the ergonomics standard are more difficult to define and to determine the cause of injury (such as carpal tunnel and low back pain), ACOEM recommend that a medical diagnosis be the basis for determining if an MSD is reportable.

An important component of OSHA's proposed standard is the requirement that employers make "MSD management" available whenever a covered MSD occurs.

ACOEM agrees with OSHA that employers should ensure injured employees are provided prompt access to health care professionals.

However, the group strongly urged OSHA to require that treatment programs and all work restrictions protection determinations "be based on a medical diagnosis made by a licensed physician, nurse practitioner, or physician assistant in those states where they are licensed for independent practice."

Finally, ACOEM noted in its comments that OSHA's proposed solution, designed to permit small employers to find an expensive and fast solution for a single work-related MSD incident, is problematic.

ACOEM recommended that OSHA "revise the quick-fix solution to encourage a workplace assessment by professionals trained in ergonomics, industrial hygiene, or safety engineering to determine if the hazard has actually been fixed."

In addition, ACOEM suggested that employees reporting acute, persistent and recurrent signs and symptoms suggestive of work-related MSDs should be provided access to a physician to provide an evaluation and diagnosis if signs and symptoms of MSD continue.

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