The Science Supporting the Standard
A substantial body of scientific evidence supports OSHA’s effort to provide workers with ergonomic protection (see the Health Effects, Preliminary Risk Assessment, and Significance of Risk sections of this preamble, below). This evidence strongly supports two basic conclusions: (1) There is a positive relationship between work-related musculoskeletal disorders and workplace risk factors, and (2) ergonomics programs and specific ergonomic interventions can reduce these injuries.
For example, the National Research Council/National Academy of Sciences found a clear relationship between musculoskeletal disorders and work and between ergonomic interventions and a decrease in such disorders. According to the Academy, “Research clearly demonstrates that specific interventions can reduce the reported rate of musculoskeletal disorders for workers who perform high-risk tasks” (Work-Related Musculoskeletal Disorders: The Research Base, ISBN 0-309-06327-2 (1998)). A scientific review of hundreds of peer-reviewed studies involving workers with MSDs by the National Institute for Occupational Safety and Health (NIOSH) also supports this conclusion.
The evidence, which is comprised of peer-reviewed epidemiological, biomechanical and pathophysiological studies as well as other published evidence, includes:
OSHA’s activities in the last 20 years shows, the Agency has considerable experience in addressing ergonomics issues.
OSHA has also used all of the tools authorized by the Act — enforcement, consultation, training and education, compliance assistance, the Voluntary Protection Programs, and issuance of voluntary guidelines — to encourage employers to address musculoskeletal disorders, the single largest occupational safety and health problem in the United States today. These efforts, and the voluntary efforts of employers and employees, have led to a recent 5-year decline in the number of reported lost workday ergonomics injuries. However, in 1997, more than 626,000 such injuries and illnesses were still reported.
Promulgation of an ergonomics program standard will add the only tool the Agency has so far not deployed against this hazard — a mandatory standard — to these other OSHA and employer-driven initiatives. Over the first 10 years of the standard’s implementation, OSHA predicts that more than 3 million lost workday musculoskeletal disorders will be prevented in general industry. Ergonomics programs can lead directly to improved product quality by reducing errors and rejection rates. In an OSHA survey of more than 3,000 employers, 17 percent of employers with ergonomics programs reported that their programs had improved product quality. In addition, a large number of case studies reported in the literature describe quality improvements. Thus, in addition to better safety and health for workers, the standard will save employers money, improve product quality, and reduce employee turnover and absenteeism.