Question 1: What is an ergonomics injury? the Department of Labor is interested in establishing an accepted definition that the Occupational Safety and Health Administration, employers and their employees can understand and apply. Question 2: How can the Occupational Safety and Health Administration, employers and employees determine whether an ergonomics injury was caused by work-related activities or non-work-related activities; and, if the ergonomics injury was caused by a combination of the two, what is the appropriate response? Question 3: What are the most useful and cost-effective types of government involvement to address workplace ergonomics injuries (e.g., rulemaking, guidelines, best practices, publications/conferences, technical assistance, consultations, partnerships or combinations of such approaches)? The agency particularly invites comment on the advantages and disadvantages of each approach or combination of approaches.

Secretary Chao's first question is: What is an ergonomics injury? The Department of Labor is interested in establishing an accepted definition that the Occupational Safety and Health Administration, employers and their employees can understand and apply. This question demonstrates a fundamental misconception about ergonomics. There is no such thing as an "ergonomics injury." Ergonomics is an applied, design-oriented science that, among many other things, can assist companies in reducing the occurrence of what OSHA has termed "musculoskeletal disorders" (MSDs). Applying ergonomics principles is a method through which MSDs, and their direct and indirect costs, can be controlled. Ergonomics is also applied to increase productivity and efficiency, reduce errors, improve quality, reduce waste, increase employee retention and satisfaction, and ultimately improve work, products, and a company's bottom-line. So, rephrasing the question for accuracy, Ergoweb respectfully suggests "What is an ergonomics injury?" be rephrased as "What is an MSD?" MSDs are injuries and disorders of the muscles, nerves, tendons, ligaments, joints, cartilage and spinal discs. MSDs can be directly and indirectly related to aspects of the work or the work environment known as risk factors. Non-work activities and environments that expose people to these risk factors can also cause or contribute to MSDs. When an MSD is associated with work it is usually referred to as a Work Related Musculoskeletal Disorder (WRMSD or WMSD). Other terms, such as cumulative trauma disorder (CTD), repetitive stress injury (RSI), and repetitive motion injury (RMI), mean roughly the same thing as MSD. However, RSI and RMI are arguably inaccurate, because these terms imply that repetition is the primary risk factor, which may or may not be the case. MSD risk factors can be defined as actions in (or out of) the workplace, workplace (or non-workplace) conditions, or a combination thereof that may cause or aggravate an MSD. Examples include forceful exertions, awkward postures, repetitive exertions, and exposure to environmental factors like extreme heat, cold, humidity or vibration. It is often a combination of these risk factors that, over time, can lead to pain, injury, and disability. These risk factors can be reduced through informed purchasing and workplace design, retrofit engineering controls, administrative controls, work practice definitions, or in some cases, personal protective equipment. The manner in which a risk factor leads to an injury/disorder is usually through the accumulation of exposure to the risk factors. An event such as lifting, pushing, or pulling may stress body tissues, yet the exposure may be too low for traumatic injury, and the tissues recover. Repeated exposure to this stress, on the other hand, may interfere with the normal recovery process and produce disproportionate responses and eventually an MSD type injury. Traumatic injuries, such as an overexertion injury, may occur due to cumulative effects that manifest themselves suddenly at the time of a specific event, or they may occur because the event exposes the body to risk factors that exceed the person's individual capabilities. A sudden back or shoulder injury tied to a specific task is an example. Ergoweb asks that OSHA refrain from using the word ergonomics in the title of any standard or guideline dealing with occupational MSDs. A more appropriate title might be "Occupational Musculoskeletal Disorder Prevention Standard," or "Occupational Musculoskeletal Disorder Reduction Standard." Qualified ergonomists, applying ergonomics principles to the design of work, equipment and processes, is a method through which risk factors that contribute to MSDs can be effectively eliminated or reduced. Ergonomics is not the problem; it is the solution. Another point of view: At OSHA's ergonomics forums in a Washington, D.C., suburb last week, business groups generally applauded the process adopted by the Department of Labor (DOL), especially the decision to focus on just three questions during the four days of forums devoted to workplace repetitive motion hazards: * What is an ergonomics injury? * How can OSHA determine when such an injury is work-related? * How should government address workplace ergonomics injuries? The AFL-CIO cried foul in part because DOL allowed more employer groups than worker advocates to speak at the forums. In addition, union members charged that DOL framed the debate by limiting the forums to the three questions raised by industry when it succeeded in scuttling the old ergo rule last March. Also many attendees were scratching their heads over the absence of the National Institute for Occupational Safety and Health (NIOSH). An OSHA spokesperson explained that neither NAS nor NIOSH had asked to participate in the forums. As if to underscore their contempt for the proceedings, after the union representatives delivered their testimony and answered questions, they departed for an AFL-CIO press briefing on ergonomics scheduled to conflict with the afternoon session of DOL's forum. Another point of view: In testimony presented at the U.S. Department of Labor's (DOL) Public Forum About Ergonomics held at George Mason University, American Society of Safety Engineers' (ASSE) President M.E. Eddie Greer, CSP, stated that there is no one-size-fits-all approach to ergonomics and provided recommendations that should be addressed when developing an ergonomic standard, if a decision is made to move forward with one. Following the repeal by Congress of the OSHA ergonomics standard earlier this year, Secretary of Labor Elaine Chao announced that public hearings would be held across the U.S. this July in an effort to determine what role the department should play in solving ergonomic problems. In his testimony to the DOL panel ASSE's Greer recommended that if an ergonomic standard is developed it should: 1) Be performance based and not use a one-size-fits-all approach to ergonomics; 2) Require an ergonomic evaluation, and be performed by a person competent in ergonomic-related issues; 3) Have the issue of a trigger mechanism be part of the public debate, as the goal of any DOL/OSHA standard is to prevent injury, illness, and fatality, and not allow an incident to take place before eliminating hazards; 4) Emphasis should be placed on improvement versus overly detailed specifications; 5) Be created through private/public sector partnerships, such as the negotiated rulemaking process, or the multiple stakeholders input process as exemplified by metalworking fluids or the proposed silica rulemaking.