Groups Announce Comments on Nursing Home Ergo Guidelines

The American Industrial Hygiene Association (AIHA) and the American Association of Occupational Health Nurses (AAOHN) have submitted comments to OSHA about the proposed ergonomics guidelines for the prevention of musculoskeletal disorders (MSD's) in nursing homes. The comment period closed Oct. 30.

The guidelines include:

  • Management practices Discusses the importance of management commitment and employee participation in ergonomics training, occupational health management of musculoskeletal disorders, and ergonomics program evaluation;
  • Worksite analysis Discusses assessment of resident handling tasks and activities other than resident handling; and
  • Control methods Contains illustrations that demonstrate various methods to control common ergonomic stressors.

The guidelines are intended to provide practical solutions for reducing ergonomic-related injuries and illnesses in nursing homes. They will not be used for enforcement purposes.

"AIHA is pleased that OSHA is addressing the issue of MSD's in nursing homes," said AIHA president Gayla J. McCluskey, CIH, CSP, ROH, QEP. "We have offered our suggestions for improvement to the guidelines. We continue to maintain that an ergonomics standard is needed," she added.

Key suggestions made by AIHA include:

  • Providing details about effective methods and tools for facilities interested in establishing formal ergonomics programs or processes.
  • Include examples of ways that employers can involve employees in the ergonomics program.
  • Include ways to make the MSD management process more effective.
  • Provide additional examples of control methods for issues other than resident handling.
  • Modify the disclaimer to explain the consequences should an employer ignore the guidelines and allow a high MSD incident rate to continue. AIHA suggests that OSHA outline its intent to pursue the General Duty Clause in cases where it is warranted.

"We hope our comments help employers and employees reduce injuries in nursing homes," said David T. Ridyard, chair of AIHA's Ergonomics Committee. "We are always happy to see steps taken to protect workers from MSD's."

AAOHN, calling the proposed guidelines "a step in the right direction," submitted its comments on the guidelines last week.

"OSHA's draft nursing home guidelines are a common-sense approach for an industry where workers suffer twice the number of ergonomics injuries than in other workplaces," said AAOHN President Deborah V. DiBenedetto. "We are pleased that the guidelines address this critical problem and provide specific information geared toward helping the industry reduce the incidence of ergonomic injuries. The challenge will be for nursing homes to ensure employees receive the appropriate training to apply this information and carry out work tasks safely."

Some of the suggestions that AAOHN included in its comments were:

  • Add an executive summary and simplify content;
  • Tailor the guidelines to multi-sized facilities, to address resource issues and challenges common to smaller nursing homes;
  • Include more information about how to implement an ergonomics program, by providing a sample of a formal, written plan;
  • Provide additional detail on how to garner management commitment; and
  • Elaborate on the training section to include more information about a regular training schedule, as well as how to train all nursing home staff not just those who will be developing the program about ergonomics procedures.

OSHA has said the National Emphasis Program will focus the agency's resources on those nursing and personal care facilities that have 14 or more injuries or illnesses resulting in lost work days or restricted activity for every 100 full-time workers. OSHA is planning to inspect approximately 1,000 of these facilities under the new NEP. Last February, OSHA notified approximately 13,000 employers -- including 2,500 nursing and personal care facilities -- that their injury and illness rates were higher than average and suggested sources of help to lower those rates.

The complete letter AIHA submitted to OSHA can be found at, while AAOHN's complete comments can be found at The draft guidelines can be found on the OSHA Web site at nursinghome/index.html.

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