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Printing Instructions |
National Advisory Committee on Ergonomics
Minutes of November 17, 2004 Meeting
|
Holiday Inn on the Hill
415 New Jersey Avenue, NW
Washington, DC
Dr. Carter J. Kerk, Chair of the National Advisory Committee on Ergonomics (NACE), opened the sixth and final meeting at 10:00 a.m.
on Wednesday, November 17, 2004. Approximately 20 members of the public were present during the course of the meeting. The following
NACE members were present:
| Edward Bernacki, M.D., MPH |
Associate Professor and Director
Occupational Medicine
Johns Hopkins University School
of Medicine
Baltimore, MD
|
| Lisa M. Brooks, CIE |
Health and Safety Program Manager
International Paper Company
Memphis, TN
|
| Paul A. Fontana |
President/CEO
Center for Work Rehabilitation, Inc. Fontana Center
Lafayette, LA
|
| Willis J. Goldsmith, Esq. |
Partner
Jones Day
Washington, DC
|
| Morton L. Kasdan, M.D., FACS |
Clinical Professor of Surgery
University of Louisville School of Medicine
Louisville, KY
|
| Carter J. Kerk, Ph.D., PE, CSP, CPE |
Associate Professor in Industrial Engineering
South Dakota School of Mines & Technology
Rapid City, SD
|
| James Koskan, MS, CSP |
Corporate Director of Risk Control
SUPERVALU, Inc.
Minneapolis, MN
|
| George P. LaPorte |
Ergonomics Manager
NATLSCO Loss Control Services
Division of Kemper Insurance Companies
Lake Zurich, IL
|
| Barbara McCabe |
Program Manager
Operating Engineers National Hazmat Program
Operating Engineers
Beaver, WV
|
| J. Dan McCausland |
Consultant
Worker Safety and Human Resources
Director
American Meat Institute
Madison, WI
|
| Audrey Nelson, Ph.D., RN |
Center Director
VHA Patient Safety Center of Inquiry
Suncoast Development Research Evaluation-Research Center for Safe
Patient Transitions
Tampa, FL
|
| Lida Orta-Anes, Ph.D. |
Associate Professor
Graduate School of Public Health
University of Puerto Rico
San Juan, PR
|
| Roxanne Rivera |
Consultant
Syntactics Communication Skills, LLC
Placitas, NM
|
| Richard Wyatt, Ph.D. |
Associate Director
Aon Ergonomic Services
Huntsville, AL
|
Attending OSHA Staff
|
|
| MaryAnn Garrahan |
Designated Federal Official
U.S. Department of Labor
Washington, D.C.
|
| Susan Sherman |
Committee Counsel
U.S. Department of Labor
Washington, D.C. |
Chair Kerk welcomed members of the public and called the roll for the Committee members. W. Corey Thompson of the American Postal
Workers Union was not present. Chair Kerk reviewed the agenda as well as the NACE charter, noting that this would be the last
meeting of the Committee and the charter would end on November 30, 2004.
Before approving the minutes from the May 2004 meeting, he asked for any corrections or changes. Dr. Lida Orta-Anes asked for
clarification on whether the Committee has begun communicating with the American Society of Safety Engineers (ASSE) to assess where
there might be mutual areas of interest. A conference call was to be set up so that the two groups could start collaborations.
Chair Kerk noted that he had previously talked with representatives of ASSE, and that the Outreach and Assistance Working Group
would address the item during their report later in the afternoon. The minutes were then approved.
Chair Kerk also noted that the Committee members had been given a document that summarized each recommendation NACE had made from
January 2003-May 2004. The list would be updated at the conclusion of this meeting.
Presentation from the Guidelines Workgroup (Part I)
Mr. Dan McCausland said that the Guidelines Workgroup had drafted additional recommendations for the development of guidelines,
outreach and assistance efforts, and research.
Mr. McCausland explained the main points of the Workgroup’s recommendations. The draft read:
- Hazards lie in the form of poorly designed work processes, and/or poorly designed workplaces. Ergonomics is a tool that may be useful in addressing those issues. Once workers no longer need to devote maximum energy to simply overcoming the physical demands of their jobs, they can devote those energies to productivity.
- There is not a widely-agreed upon definition of musculoskeletal disorders (MSDs), so the Workgroup decided that the pursuit of a definition of MSDs is unproductive, suggesting that NACE, OSHA, and others should continue their work and not get caught up in finding a definition.
- MSDs, by any definition, cannot be exclusively linked into a cause-and-effect relationship with specific ergonomic problems. The common and proper objective of ergonomics is to reduce to a practical minimum the physiological consequence of doing specific types of work. To this end, a number of tools and guidelines may be useful, such as the NIOSH lifting guideline.
- Ergonomics should be included in comprehensive occupational safety and health programs. Ergonomics should be integrated into business processes in the same way as job safety analysis, air and noise sampling, PPE hazard assessments, process hazard analysis, and similar tools.
- It must be recognized that there are non-occupational components (e.g., leisure, play, physical daily living activities), that also contribute to the occurrence of MSDs. We must protect our employees when they are at work, but we must also educate them about the kinds of things that can cause problems outside of the workplace.
Mr. McCausland recommended that the Committee should adopt these points and recommend them to OSHA.
Dr. Orta-Anes recommended adding the following sentences to the first point: “Ergonomics is a noun, not an adjective,” and “It is
recommended that it is used in formal documents as such.”
She next recommended that in the first point, ergonomics be defined as a process, not a tool. She also recommended that point
two and three be combined and the information regarding the pursuit of a definition of MSDs be eliminated. She asked that the
third point be altered to read: “MSDs are a consequence of exposure to risk factors of a multi-factorial nature. The common proper
objective of ergonomics is to control these risk factors, hence reducing the physiological cost of doing work. To this end, a number
of tools and guidelines may be used.”
Mr. McCausland said the Guidelines Workgroup would modify the first point per Dr. Orta-Anes’ suggestion since it was consistent with
the intention of the Workgroup. He also agreed to change the word “tool” to “process.”
He explained that they had kept the definition issue separate from tools and guidelines because they were each important enough to be
their own point.
Dr. Audrey Nelson asked for clarification on whether the Workgroup’s recommendation was to adopt the five points as a whole or to
recommend the five points separately.
Mr. Paul Fontana said the list was to be considered for the purpose of guidelines development, and therefore, the points did not need
to be treated as individual recommendations. He added that the intent was to have the Committee on record as saying it is not
important to focus on the single issue of developing a definition of MSDs.
Dr. Morton Kasdan asked that the group add “general health” to the list of examples in number 5.
Ms. Lisa Brooks commented that the recommendation limited the use of the term ergonomics to only the physical demands of the
workplace, when ergonomics is broader than that and can do more than address just MSDs. She asked if the first sentence in
number 1—“the human interface with the work system”—involved more than just the physical side of work.
Mr. Fontana suggested adding “psychosocial”,among other terms, to the list of examples, to show the expansiveness of MSD
causation.
Ms. Brooks said if the examples provided in the list refer to the physical side of work and ergonomics, she would be comfortable
with that.
Mr. Fontana said it would be fine to add “behavioral”, “cognitive,” or other terms there.
Chair Kerk commented that he thought the Committee agreed with the recommendation in general, but wanted to see a few words changed.
He suggested that the Workgroup and anyone else interested in commenting on the recommendation meet privately to discuss any
further changes and then report back to the full Committee.
Mr. McCausland asked if Ms. Brooks would be satisfied if the word “physical” were removed from the statement.
Ms. Brooks replied that it would be a step in the right direction.
Mr. Koskan said the Guidelines Workgroup had another issue they wanted to present to the entire Committee for feedback. Mr. Koskan
referred to the fifth point in the Committee’s Charter: “Ways to increase communication among stakeholders on the issue of
ergonomics.” He said the Committee had heard testimony about the notion that off-the-job exposures, which significantly impact
the risk of MSDs, must be addressed when assessing workplace problems. Given that assumption, he asked if it was within the
bounds of the Committee’s charter to recommend that OSHA form partnerships and share information with organizations that deal
with disorders occurring outside the workplace.
Ms. Barbara McCabe said it is important to consider the worker in what is effective and what is not. She said that when workers are
trained and educated about ergonomics, much of what is learned filters to workers’ actions outside of the workplace.
Mr. Koskan clarified his question, asking whether the Committee has a responsibility to make a recommendation to OSHA to establish
some liaisons and partnerships with the public health community.
Chair Kerk asked for further comments and then tabled the discussion of the Guidelines Workgroup’s recommendation.
Presentation from the Research Workgroup
Ms. Roxanne Rivera led the presentation for the Research Workgroup. She thanked OSHA and Tom Waters of NIOSH for their help over the
past 2 years. She reviewed the research component of the NACE charter, emphasizing that the group was tasked with identifying
gaps in the existing research base related to applying ergonomic principles to the workplace, and also current and projected
research needs and efforts.
She indicated that the Workgroup had identified eight research gaps and was recommending that the Committee recommend to
OSHA that they work to address those research needs. She explained that, like the other Workgroups, the Workgroup used the
term MSDs but chose not to define the term. The Workgroup concluded that:
- More research is needed to examine the validity of techniques used to establish MSD diagnosis.
- More research is needed to examine the role of psychosocial factors that contribute to or impact the development of MSDs
.
- Studies are needed to develop additional animal models in which the effects of physical loading on living tissues can be studied
in a controlled manner.
- Additional studies are needed to:
- Examine the validity and reliability of existing exposure assessment methods,
- Develop additional assessment methods.
- Additional studies are needed to determine the economic impact to organizations of what are commonly described as ergonomic
interventions.
- More studies are needed to address the multi-factorial causes of MSDs, such as psychosocial, occupational, and non-occupational
factors and their interactions.
- Additional studies are needed to describe the natural history of diseases or injuries commonly known as MSDs.
- Studies are needed regarding factors in Workers’ Compensation systems and other statutory payment mechanisms on findings of
causation, diagnosis, the duration of the disability, and other potential effects of MSDs.
Mr. James Koskan asked for clarification between the second and sixth point.
Mr. Willis Goldsmith explained that by highlighting psychosocial factors in the second point, the Workgroup was trying to emphasize
that of all of the multi-factorial causes that are related to MSDs—psychosocial factors, in particular—need more research. He
continued that the sixth point addresses the need for research that both isolates individual causes and determines how those
individual causes relate to each other.
Dr. Morton Kasdan confirmed that behavior was included in the psychosocial component.
Mr. McCausland commented that many of the gaps were consistent with the Guidelines Workgroup’s presentation. He also asked about
the Research Workgroup’s decision to not define MSDs.
Dr. Orta-Anes explained that there was a lengthy discussion about the definition of MSDs, but in the end the Workgroup decided to
define them in the context of what they were discussing.
The Committee reached consensus and approved the Research Workgroup’s recommendation to forward the list of research gaps to OSHA.
Presentation from the Guidelines Workgroup (Part II)
Mr. McCausland reviewed the Workgroup’s changes. He noted that they had not changed the opening statement. He then read the revised
first point to the Committee, noting several changes to the wording. The revised first point read:
“Ergonomics is a noun, not an adjective, and it is recommended that it is used as such in formal documents as it exists
in the form of poorly designed work practices and/or workplaces. Ergonomics is a process that can be beneficially used to address job
and workplace design—the human interface with the work system. Improved safety characteristics occur in concert with productivity
improvements. Once workers no longer need to devote maximum energy in overcoming the demands of their work practices and/or
workplaces, they can devote those same energies to productivity and quality aspects of their jobs.”
Dr. Ed Bernacki said the statement seemed to have two thoughts. One, that ergonomics is a noun. The other, that ergonomics is a
process.
Mr. McCausland explained that the Workgroup was trying to distinguish the noun “ergonomics” from ergonomics hazards, and to identify
ergonomics with injury and illness problems, rather than being a process.
Mr. McCausland read the second point, which was changed significantly. He acknowledged that saying the “pursuit of a single
definition of MSDs has not reached consensus” was more accurate than saying the “pursuit of a definition has not been productive.” He
explained the Workgroup’s intent was to suggest that OSHA not let the issue of definitions delay other parts of the analysis. The
revised second point read:
“The pursuit of a single definition of MSDs has not reached consensus. Various and numerous MSD definitions cover a host
of conditions limited only by those doing the defining, none of which directly help to reduce the number of such disorders. OSHA
should continue development of guidelines independent of any final definition of MSDs.”
Mr. McCausland moved on to the third statement, where he said the Workgroup inserted the idea that MSDs occur as a consequence of
exposure to multi-factorial risk and that the objective is to control and reduce the exposure to those risks. The group had made
a list of examples rather than an all-inclusive list. The revised third point read:
“MSDs by any definition cannot be exclusively linked into a cause and effect relationship with specific ergonomic
solutions. MSDs are a consequence of exposure to risk factors of a multi-factorial nature. The objective of ergonomics
applications is to reduce to a practical minimum the demands, for example, physiological, cognitive, behavioral, of doing
the work by controlling these exposures. To this end, a number of tools and guidelines may be useful.”
Mr. McCausland said there was still a discussion about the first sentence of the third point regarding cause and effect. Dr.
Orta-Anes wanted it removed from the statement. The Workgroup did not want to remove the statement because they thought that it was
true. Mr. McCausland said there was apparently data in some of the NAS reports that more explicitly link the causes of MSDs to
particular exposures, but he felt the common understanding is that in general, one cannot exclusively attribute a particular
exposure to an MSD.
Mr. McCausland asked Dr. Orta-Anes to explain her thinking on the third point.
Dr. Orta-Anes said she did not find value in the first sentence and did not believe it to be true. She explained that there are
two NAS studies that address specific causes and effects of ergonomic problems, which is why she did not feel comfortable with
the first sentence.
Mr. McCausland explained that the reason the Workgroup left the first sentence in the statement was to convey that a number of
tools and guidelines may be useful regardless of whether or not they have been shown to have a direct link to MSD prevention.
Ms. Susan Sherman suggested changing the first sentence to read: “Not all MSDs by any definition can be exclusively linked into
a cause and effect relationship with specific ergonomic solutions.”
The Committee had a brief discussion of possible word changes to make the sentence acceptable.
Mr. Goldsmith said the point as written was accurate and it should not be changed. He added that there will always be studies that
purport to have discovered a specific cause, but he did not feel any of those reports had been adequately tested.
Dr. Bernacki said he agreed with Dr. Orta-Anes, that the statement was too harsh, even though it has validity.
Mr. Tom Waters from NIOSH suggested the statement begin by saying “The exact cause of a specific MSD may not be known, however…”
Mr. Goldsmith said Mr. Waters’ suggestion might work. He reiterated his previous statement that he didn’t think there was any
legally sustainable study that could point out that there is a precise or exact relationship between a cause or effect and an MSD.
Mr. Koskan said that although the idea in the first sentence has been a topic of debate for years, he believed the statement is
factual. He said that given Mr. Waters’ statement, perhaps the group had more work to do on the statement.
Mr. McCausland said the Workgroup was willing to continue the discussion on the third point. In regards to Mr. Waters’ comment,
Mr. McCausland explained that the reason the group originally said “exclusively linked” was to clearly indicate that an exact
relationship does not exist, even if there may be some evidence of a correlation.
Mr. McCausland explained the only change to the fourth point was the removal of “air and noise sampling” since those terms were
rather discrete.
Mr. McCausland read the fourth point for the record and then introduced the fifth point, in which the only change was the
addition of the words “general health” to the list of examples.
Chair Kerk asked the Committee to table the discussion again to work on the third point.
Mr. Koskan asked if the Committee could accept the rest of the points.
Chair Kerk said it would be cleaner to keep the points as a unit; the Committee disagreed, however, and therefore Chair Kerk
asked for consensus on the guidance, excluding the third point. The Committee reached consensus.
Presentation from the Outreach and Assistance Workgroup
Dr. Nelson provided a brief overview of the various activities the Workgroup had worked on during the
past 2 years, including:
- Exploring literature and inviting guest speakers.
- Examining ways to build a business case for ergonomics (e.g., by recommending a resource guide to address the cost-benefit of
interventions).
- Reviewing social marketing strategies for promoting ergonomics at all levels.
- Providing recommendations for ways to enhance the OSHA Web site.
- Creating an “Early Adopter’s Program” that would encourage individuals to implement a guideline when it is published.
- Recommending best practice forums.
- Establishing a better process for collecting and presenting success stories within OSHA.
Chair Kerk provided an update on the Workgroup’s interaction with the ASSE, noting that the Workgroup had liked the nature of ASSE’s
proposal and felt it was a worthwhile effort on their part. He added that ASSE was not invited to speak at the NACE meeting due
to time constraints, but he had contacted them to encourage them to continue with their efforts.
Ms. Brooks provided details on the modified version of the template for reporting ergonomics success stories, noting that the
template was e-mailed to all the Committee members prior to the November meeting. She added that after receiving feedback and
incorporating comments, the Workgroup is recommending that OSHA consider the following areas for improving the ergonomics success
story collection and distribution process:
- Consider providing a form, or developing a form or template for submissions (perhaps similar to the sample form provided by the
Workgroup).
- Include a disclaimer acknowledging that the success stories had not been peer-reviewed, and enhance the prominence of the
disclaimer currently on the success stories section of the OSHA Web site.
- Consider providing examples of success stories.
- Consider incorporating keyword searches and sorting capabilities into the success stories published on the Web site.
Mr. Koskan asked whether there was a section on the template that asked people to identify financial benefits of
ergonomics programs.
Ms. Brooks confirmed that both short- and long-term costs of the programs were included in the data being collected.
Ms. Brooks reminded the Committee that the Workgroup was asking OSHA to consider enhancing the process in any or all of the
four suggested ways. She explained that OSHA did not necessarily have to use the exact form created by the Workgroup—it was
meant only as a starting point.
Mr. Koskan asked who at OSHA reviews the success stories before publishing them.
Ms. Beth Sherfy of OSHA explained that a law firm in Atlanta is under contract to review success stories. OSHA also reviews
the stories before publishing them.
Ms. Susan Sherman, Department of Labor’s legal counsel for NACE, introduced the template into the record as Exhibit 1. She
also identified the Workgroup’s two examples of success stories as Exhibit 2.
The Committee reached consensus on the Workgroup’s recommendation that OSHA consider enhancing the success story collection
and presentation process.
Presentation from the Guidelines Workgroup (Part III)
Mr. McCausland said the Guidelines Workgroup met with several members of the Research Workgroup, but that they still did not
have a full consensus on the third point.
Mr. McCausland read the point for the record:
“MSDs are a consequence of exposure to risk factors of a multi-factorial nature. Control of MSDs cannot always
be exclusively linked into a cause and effect relationship with a specific intervention. The objective of ergonomics is to
reduce to a practical minimum the demands (e.g. physiological, cognitive, behavioral) of doing the work by controlling these
exposures. To this end, a number of tools and guidelines may be useful.”
Mr. McCausland explained the changes made to the statement.
Mr. Goldsmith said he was not familiar with examples of situations where an MSD can be exclusively linked to a cause and effect
relationship with a certain intervention, and he asked for those examples to be put on record along with their source.
Dr. Bernacki asked if the point of the statement was to urge OSHA to come up with multiple tools to discover a link between
interventions with the prevention of MSDs.
Mr. McCausland responded that the intent was to indicate that a number of tools and guidelines may be useful in the process of
reducing, to a practical minimum, the demands of doing work.
Mr. Fontana said the key is the link between cause and effect, and it is important to emphasize that the cause and effect is
unknown in most cases.
Mr. Goldsmith agreed with Mr. Fontana but did not feel that was what the statement conveyed.
Ms. Brooks said she sees the term “cause and effect” more commonly used with hazards causing injuries or illnesses, (in this case,
MSDs), than with interventions against those hazards. She said that she interpreted the sentence to say that there are some
interventions that may control an MSD. She told the Committee to recognize that the statement had been switched from “cause
and effect of hazards of MSDs” to “cause and effect of interventions preventing MSDs.”
Mr. McCausland told Ms. Brooks her statement conveyed exactly what the group was trying to say, that no specific intervention
can be prescribed to prevent ergonomic injuries.
Mr. McCausland said people at some workplaces are given partial information and believe that if they perform certain actions,
the risk of MSDs will be eliminated. The Guidelines Workgroup did not believe that to be the case.
The Committee had further discussion regarding the wording of the statement.
Dr. Nelson said she had a problem with the second sentence [Control of MSDs cannot always be exclusively linked into a cause
and effect relationship with a specific intervention], which she said implies that unless a direct cause/effect relationship
is established, no other evidence is important. She did not think that statement was true because a variety of different
mechanisms have been examined through methods other than randomized control trials. She felt the statement implied that
the randomized control trial that determines cause and effect is the only thing of value.
Mr. McCausland said the Guidelines Workgroup agreed with Dr. Nelson, and it is trying to say that, although these things may
not have been proven to be exclusively linked in the cause and effect relationships with any specific intervention, a number
of tools and guidelines may still be useful.
Mr. McCausland said the Workgroup is specifically staying away from any questions that have to do with ergonomics standards.
Dr. Nelson said the statement would make sense without the second sentence, which she recommended deleting.
Mr. Koskan did not agree with Dr. Nelson because he felt the statement was factual. He suggested the Committee take a vote
to see if the majority of the group was willing to accept the wording of the statement. He said he knew some of the
Committee members felt it was important to state that this cause and effect relationship does not exist, except in perhaps
some specific situation with a very unique control and a very unique exposure.
Ms. Brooks said there are times when certain interventions have eliminated hazards. She also admitted that there might be
times when they do not, and the difficulty is in knowing when. She said the challenge was in understanding how people were
interpreting the second sentence, and she recommended eliminating it.
Mr. McCausland asked the Committee for another chance to talk with the Guidelines Workgroup in hopes that they might be able
to do adjust the wording.
Chair Kerk said the issue would be tabled again and said unless anything changed, there was a motion and a second to delete
that sentence.
Assistant Secretary of OSHA, John Henshaw
Mr. John Henshaw, Assistant Secretary of OSHA, arrived and thanked the Committee for their work, noting that NACE had helped
OSHA move forward in addressing ergonomics in American workplaces.
Chair Kerk reviewed the Committee’s list of recommendations to date, referring to the handout provided to the Committee.
Dr. Nelson also summarized the Outreach and Assistance Workgroup’s progress to date.
Mr. Henshaw provided an overview of the progress OSHA has made on each of the components of the four-pronged comprehensive
approach to ergonomics: guidelines, outreach and assistance, research, and enforcement.
Mr. Henshaw noted that OSHA has conducted 1,900 ergonomics inspections since 2002 and has issued 16 citations and nearly 376
hazard alert letters. He added that OSHA has also sent nearly 85 letters to sites acknowledging various organizations’ efforts
to reduce workplace MSDs.
Mr. Henshaw said that OSHA has made improvements to its Web site and appreciates NACE’s effort in identifying research gaps
and potential industries for future guidelines.
He stated that although the NACE charter is expiring, OSHA will continue to move forward on ergonomics issues and working to
reduce the incidence of MSDs. He also summarized the cooperative efforts OSHA has undertaken with its 25 strategic
partnerships, including the United States Postal Service. Mr. Henshaw also explained that the Industry Exchange Group
between NIOSH and OSHA might soon form a subgroup devoted to ergonomics. In addition, OSHA plans to present at the next
National Occupational Research Agenda (NORA) meeting.
Chair Kerk thanked Mr. Henshaw and OSHA for the opportunity to serve the Department of Labor, noting that he had observed
the hard work of NACE throughout its charter.
Presentation from the Guidelines Workgroup (Part IV)
Mr. McCausland said it was apparent in the last discussion that the term “cause and effect” had a negative connotation for
some people. In order to remove this term, the statement was altered to read:
“MSDs are a consequence of exposure to risk factors of a multi-factorial nature. Other than eliminating the task in
question, the effect of any specific intervention cannot be linked to a specific outcome. As such, the objective of ergonomics
is to reduce, to a practical minimum, the demands (e.g., physiological, cognitive, behavioral) of doing the work by controlling
these exposures. To this end, a number of tools and guidelines may be useful.”
Dr. Nelson said she appreciated the fact that the group removed the “cause and effect” but the new sentence says the effective
intervention and the outcome are the same thing, which is grammatically incorrect.
Mr. Goldsmith agreed with Dr. Nelson and suggested replacing “linked to a specific outcome” with “predicted.”
Dr. Nelson suggested saying “an outcome cannot be linked to a specific intervention.”
Mr. Fontana said he felt the statement was getting off track from its original intent. He said the original intent was to say
that even though the exact cause and effect of MSDs are unknown, the problem should still be fixed.
Chair Kerk asked for consensus on the statement without the adjustments. The Committee did not reach consensus so Chair Kerk
asked for a specific plan to modify the statement.
Mr. Koskan suggested incorporating Mr. Goldsmith’s change.
Mr. Goldsmith repeated his suggestion and it was added to the statement.
Dr. Nelson said the statement, with several incorporated changes, now puts the “prediction” and “uncertainty” with “intervention”
and changes the intent of the message. She recommended deleting the second sentence, but modifying the first sentence to read:
“MSDs are a consequence of exposure to risk factors of a multi-factorial nature, and cannot be easily predicted.”
Chair Kerk asked Dr. Nelson if she wanted to eliminate the second sentence. Dr. Nelson said she did.
Chair Kerk asked for consensus on the statement without the second sentence.
Mr. LaPorte agreed, saying the Workgroup addresses the cause and effect issue by bringing up the question of whether ergonomic
injuries can be easily predicted.
Chair Kerk asked for consensus on the statement.
Mr. Koskan disagreed, saying the new wording implies that more is understood about the relationship between initiatives and
outcomes than really is. He said the new statement is too weak, but he would be comfortable if the idea of eliminating the
job was brought back into the sentence.
Mr. Goldsmith suggested replacing the word “easily” with “with any degree of certainty.”
Dr. Orta-Anes disagreed saying the current wording recognizes the fact that there are not predictions.
Mr. Koskan asked Chair Kerk to clarify what he meant by consensus, saying there have been times throughout the discussion where
a majority could have ruled, but the debate continued in an attempt to get 100 percent consensus.
Ms. Susan Sherman said consensus is general agreement, as opposed to unanimity, which is universal agreement.
Mr. Koskan said, given that definition, he thought the Committee was close to a general agreement a few versions ago.
Ms. Rivera suggested the Committee vote on the statement as is to see where the Committee stood before words were eliminated,
per Mr. Goldsmith’s suggestion.
Dr. Orta-Anes agreed with Ms. Rivera, suggesting that the Committee vote on the statement before the latest changes were
implemented.
Mr. Tom Waters suggested new wording for the second sentence, which read, (after a few revisions):
“Although the exact cause of specific MSDs may not be known, and the precise effectiveness of an intervention may not
be predictable, the objective of ergonomics is to reduce to a practical minimum the demands, such as physiological, cognitive,
behavioural, of doing the work by controlling these exposures.”
Chairman Kirk then read the entire statement which included Mr. Waters’ revised second sentence, as follows:
“MSDs are a consequence of exposures to risk factors of a multi-factorial nature. Although the exact cause of a
specific MSD may not be known, and the precise effectiveness of an intervention may not be predictable, the objective of
ergonomics is to reduce to a practical minimum the demands, such as physiological, cognitive, behavioral, of doing the work
by controlling these exposures. To this end, a number of tools and guidelines may be useful.”
The Committee reached consensus on the new statement.
The final recommendations for Guidelines as approved by the Committee:
The National Advisory Committee on Ergonomics, at its final meeting, has developed the following points with the
intent that they will be useful to guide OSHA concerning the development of future guidelines, outreach and assistance, and
research.
- Ergonomics is a noun, not an adjective. It is recommended that it is used as such in formal documents. Hazards exist in the
form of poorly designed work practices and/or workplaces. Ergonomics is a process that can be beneficially used to address job
and workplace design – the human interface with the work system. Improved safety characteristics occur in concert with
productivity improvements. Once workers no longer need to devote maximum energy to “overcoming” the demands of their work
practices and/or workplaces, they can devote those same energies to productivity and quality aspects of their jobs.
- The pursuit of a single definition of MSDs has not reached consensus. The various numerous MSD definitions cover a host
of conditions, limited only by those doing the defining, none of which directly help to reduce the number of such disorders.
OSHA should continue the development of guidelines independent of any final definition of MSDs.
- MSDs are a consequence of exposures to risk factors of a multi-factorial nature. Although the exact cause of a specific
MSD may not be known, and the precise effectiveness of an intervention may not be predictable, the objective of ergonomics
is to reduce, to a practical minimum, the demands, such as physiological, cognitive, behavioral, of doing the work by
controlling these exposures. To this end, a number of tools and guidelines may be useful.
- Ergonomics should be included in comprehensive occupational safety and health programs. Ergonomics should be integrated
into business processes in the same way as job safety analysis, personal protective equipment hazard assessments, process
hazard analysis, and similar occupational safety and health tools.
- It must be recognized that there are non-occupational components, such as general health, non-work, leisure, play, and
physical daily living activities) that also contribute to the development and occurrence of MSDs. To reach outside the work
arena, these components are best addressed by educating the workforce concerning such non-work hazards.
Public Comment
Mr. Dave LeGrand, Director of Occupational Safety and Health with the Communications Workers of America, suggested that NACE
recommend to Mr. Henshaw a very strong, aggressive enforcement identification and resolution program on behalf of OSHA. He
explained that since the revocation of the OSHA ergonomics standard, many companies are determining work-relatedness of MSDs
based on Workers’ Compensation data, which is misleading.
Chair Kerk thanked Mr. LeGrand for his comments and asked if anyone from the public wanted to comment.
Mr. Tom Waters thanked the Committee on behalf of Dr. John Howard and NIOSH for allowing them to be involved with NACE.
Chair Kerk adjourned the meeting.
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