OH.com Exclusive Series: OSHA, Ergonomic Guidelines and Expert Opinions
In this series of articles exclusive to the Web, OH.com asks leading ergonomic experts what they think about OSHA.
(Since this interview took place, OSHA announced it would formulate ergonomic guidelines for retail grocery stores and the poultry processing industry.)
Question: What is your role in the over-all four-pronged OSHA ergonomics effort?
Answer: Co-chair of OSHA's ergonomics steering committee. Davis Layne is the other Deputy Assistant Secretary of Labor and the other co-chair of the committee. We share all four prongs equally.
Q: Who is the expert ergonomist at OSHA leading the guidelines effort?
A. We have resources around the country, and are still surveying and pulling that list together. We're not relying solely on a person to draft those guidelines. They're being done collaboratively by a number of people.
We have a pool of people some of whom are certified who we regard as our experts on ergonomics. They will be involved in various levels of reviews of these guidelines. The people actually doing the legwork on these guidelines have some background in ergonomics but they're people who are experts in writing those things and they are working with people who have expertise in the subject matter.
We're really counting on the expertise spread around the country. They'll also be useful for outreach and assistance for enforcement. We do have an ergonomist here. [Editor's Note: Visscher is referring to Roger Stephens, who is retiring in less than a year.] We're evaluating whether you want to add to the ergonomic expert pool in Washington. We think we're fairly deep around the country. [OSHA Administrator] John Henshaw's view is it may be more important to have someone closer to the OSHA Training Institute where we send our compliance officers for updating and training. He's not married to the idea that we need to have people in Washington.
Q: Who is the person leading ergonomics enforcement under the General Duty Clause?
A: Rich Fairfax, compliance director, is working very closely with the solicitor's office. In this regard, the nursing home national emphasis program should be finalized shortly. It is a national emphasis program and the initial part is outreach, then enforcement follows after that. It includes ergonomics, bloodborne pathogens, slips and falls, TB - the 4 main causes of injury in nursing homes.
Q: For purposes of enforcement and guidelines, what is the current official OSHA definition of a repetitive motion or ergonomic injury?
A: We don't need a specific definition of this kind of injury for either enforcement or guidelines. One of the strengths of our non-regulatory approach is we can focus on root problems.
What we look for is:
- Whether there is a hazard causing injuries.
- Is the hazard recognized, does employer know, or should employer know.
- Are the injuries causing serious physical harm.
- Are there feasible means of abatement?
With guidelines too, we will define ergonomic issues in terms of that particular guideline. We don't have to get into whether it's repetitive or a single instance. What are the prevalent problems in that injury? That's one of the strengths of guidelines: we don't have to get into a single definition.
We will announce by June 30 what we'll do in 2003 on recordkeeping with respect to MSD reporting and the threshold for hearing loss. In the meantime, we can take a practical approach.
Q: What about the education level of OSHA's ergonomic COs? OSHA has ergonomic experts in its Regional Offices. How many are certified?
A: I don't know.
Q: Are there plans to push for the certification of ergo experts?
A: I don't know.
Q: Are there currently ergonomic experts in area offices? How many and how many are certified?
A: Most area offices have people who have had at least some background and training in ergonomics. In many cases they've done inspections most have had some ergonomics training and taken some courses.
Q: Does OSHA have specific plans to improve the ergonomic education of its compliance officers?
A: Yes. There will be a renewed effort to make sure the compliance officers are trained in ergonomics.
I think it's next month we're doing a major training program on the nursing home issues, and a lot of it will be on ergonomics. Before we launch the national emphasis program I mentioned earlier we're doing a major training program for our compliance officers.
We have regional ergonomic coordinators and we are working with them to be sure they're trained. They in turn will carry a significant load to make sure the people in their regions feel comfortable with ergonomics and are properly trained. And as we move forward we'll be doing additional training programs also for the compliance officers. There will be a renewed effort to make sure the compliance officers are trained in ergonomics.
Q: Does OSHA have any specific enforcement goals in place to evaluate its own success or failure in this area? Target dates for progress?
A: We have no specific enforcement goals. It will depend on the rest of our program. The nursing home emphasis program will direct a fair amount of our enforcement. We're also using our site-specific targeting system (SST), which identifies high injury workplaces and those that are in industries that appear to have a significant problem with ergonomic-related injuries. We're using our emphasis program and our SST primarily to direct our inspections. From there it depends where our inspections take us, whether they will lead to citations, hazard alert letters, or nothing.
Q: Is OSHA planning on doing general industry guidelines? I have been told by sources within the agency that these guidelines already exist at OSHA. In addition, some companies that have operations in a number of different sectors may prefer general industry guidelines rather than having to cope with a number of different documents for different sectors.
A: General industry guidelines? The decision the [Secretary of Labor Elaine Chao] made is to go with industry- and task-specific guidelines, rather than broad elements that might be useful for all places. She believes that one of the problems with the previous regulation was that it was so broad it lost its usefulness. Guidelines are useful if they're more specific to that particular industry.
Q: Who is OSHA talking to in the health care sector in its effort to develop guidelines here? In my own reporting, I have found companies often reluctant or unwilling to talk about their best practices because of competitive concerns. Some companies have spent a lot of money determining how to solve problems that save them money and don't want to give this information away for nothing. Is OSHA finding this hurdle?
A: We're working with associations and unions on this. I'm not surprised that you have found companies reluctant to talk about ergonomic best practices. I think we'll be more successful at working with associations.
We've had conversations with specific companies. We're still feeling our way on how much help they will be in developing guidelines. They have indicated they are willing to work with us. As we proceed along here I think we'll find out whether they prefer to work through associations. For competitive reasons they may well be reluctant to share a lot of information with us.
Q: What criteria does OSHA use to determine which sectors will get guidelines?
A: Criteria we use to select industries for guidelines are:
- Industries with relatively high ergo related injury rates.
- The existence of recognized practical solutions, control methods in that industry, we cant' be pushing the envelope and developing new science.
We prefer those industries that want to work with us. That's not a veto they have, if we decide a certain industry needs a guideline we're going to do it regardless, but we want to work with people.
So far that has not been a problem with the industries we have identified as good candidates for guidelines.