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NIOSH Testimony to OSHA
Comments on the Proposed Ergonomics Program

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NIOSH Testimony to OSHA
Comments on the Proposed Ergonomics Program

29 CFR Part 1910 Docket No. S–777

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES Public Health Service Centers for Disease Control and Prevention National Institute forOccupational Safety and Health

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Ordering Information
To receive documents or more information about occupational safety and health topics, contact the National Institute for Occupational Safety and Health (NIOSH) at NIOSH—Publications Dissemination 4676 Columbia Parkway Cincinnati, OH 45226–1998 Telephone: 1–800–35–NIOSH (1–800–356–4674) Fax: 513–533–8573 E-mail: Pubstaft@cdc.gov or visitthe NIOSH Web site at www.cdc.gov/niosh

This document is in the public domain and may be freely copied or reprinted. Disclaimer: Mention of any company or product does not constitute endorsement by NIOSH.

Note to the Reader: This publication incorporates minor changes in wording for grammar and consistency that were identified in the written testimony to the OSHA docket.

DHHS (NIOSH)Publication No. 2001–108 November 2000

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Introduction
he National Institute for Occupational Safety and Health (NIOSH) is pleased to provide testimony in support of the Occupational Safety and Health Administration (OSHA) proposed rule on ergonomics [64 FR 65768]. NIOSH supports this ergonomics program standard addressing the significant risk of work-related musculoskeletaldisorders (MSDs) in general industry. The preamble to the proposed rule provides compelling data indicating that work-related MSDs are a very large problem for the U.S. economy. The importance of work-related MSDs is also reflected in NIOSH experience in intramural and extramural research (funded internally and externally) and the health hazard evaluation program (all health hazard evaluation reports areavailable from the National Technical Information Service). NIOSH is conducting ergonomic research and responding to ergonomic concerns of employers and workers across a wide range of U.S. industries and occupations. Also, through the National Occupational Research Agenda (NORA), NIOSH has identified a strong consensus for work-related MSDs as a top research priority among our diversestakeholders—a broad range of industry, labor, academia, and government groups. During our 29 years of existence, NIOSH has amassed research and experience that establishes a clear relationship between specific workplace hazards and specific MSDs. We believe, therefore, that there is a large and more than adequate science base for rulemaking. What OSHA has proposed—a standard that addresses hazardidentification, hazard control, training, MSD management, and program evaluation—is strongly supported by this science base and our professional experience. The proposed ergonomics rule includes scientifically valid and feasible requirements, which, if widely implemented, will reduce the economic and human burden of one of the largest occupational health problems in the U.S. 1

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The preamble to theproposed rule provides compelling data indicating that work-related MSDs are a very large problem for the U.S. economy.

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Musculoskeletal Disorders
This proposed standard addresses the significant risk of workrelated MSDs confronting employees in various jobs in general industry workplaces. MSDs include a group of conditions that involve the muscles, tendons, joints, nerves,ligaments, cartilage, and supporting structures (such as intervertebral discs). Some MSDs have specific diagnostic criteria and clear pathological mechanisms (e.g., carpal tunnel syndrome). Others are defined primarily by the location of pain and have a more variable or less clearly defined pathophysiology (e.g., back disorders). MSDs represent a wide range of disorders, which if not treated can...