September 15, 2003

OSHA Docket Office
Docket No. GE2003-2
Room N-2625
U.S. Department of Labor
200 Constitution Ave., NW
Washington, DC 20210

Re: Ergonomics for the Prevention of Musculoskeletal Disorders: Draft Guidelines for Poultry Processing

The American Association of Occupational Health Nurses, Inc. (AAOHN) is pleased to submit our comments on OSHA's draft ergonomics guidelines for poultry processing.

General Comments

In general, the draft guidelines contain a great deal of useful information. They focus on various solutions that have been implemented by poultry processing plants and generally mirror the meatpacking guidelines (1993) providing assistance with problem solving and clear instructions. The guidelines provide a systematic approach for prevention of musculoskeletal disorders (MSDs) through work practices that minimize exposure to ergonomic stressors. AAOHN supports OSHA's effort to provide practical recommendations to help poultry processing employers and employees reduce the number and severity of MSDs in the workplace.

To address ergonomic stressors in the work environment, we maintain that guidelines should be based on three principles.

1. Prevention: Any ergonomics strategy should be designed to assist employers in identifying safety hazards and correcting them before injury or illness occurs.
2. Clarity: It is important for guidelines to be clear so that employers can easily understand the benefits of preventing MSDs to workers.
3. Employer Incentive: Guidelines should encourage employers to develop an ergonomics program through measures that positively impact the bottom line. It is also important that the OSHA guidelines address the importance and value of competent medical management of MSDs, the amount of physical effort required to perform a task and the need for training both prior to job assignment and periodically thereafter.

AAOHN would like to take this opportunity to provide additional specific comments on the draft guidelines for poultry processing.

Specific Comments

Health Care Providers Section:

• We recommend changing the term "health care provider to "licensed health care provider" to ensure that only qualified health care professionals administer evaluation and treatment of MSDs. Occupational and environmental health nurses (OHNs) are already trained in MSDs and provide essential, cost effective services to poultry processors.

Poultry processors need valid data to develop a competent medical management plan for MSDs in the workplace. The guidelines should assist employers in the reporting, assessment, treatment and follow-up of such disorders by:

• Encouraging employees to report problems without fear of reprisal so that the disorder may be addressed prior to a disabling condition occurring.
• Recognizing transitional or modified work as one of the more effective forms of treatment that, in many cases, allows the specific body part time to rest without taking the employee off the job for a period of time.
• Reinforcing effective healthcare management practices such as adequate staffing and appropriate facilities.
• Using the hierarchy of controls for hazard management, start with engineering controls first, followed by administrative/work practices, then as a last resort, personal protective equipment.

The guidelines provide many useful diagrams to protect the workers by offering ergonomics solutions. We recommend the following changes:

• In the Workstations diagram, provide an adjustable back support to the work stool as opposed to the freestanding back support on a pole.
• Incorporate the use of anti-fatigue mats, which reduce fatigue and promote circulation.

We agree with OSHA that training is critical so that employers and employees can use the guidelines effectively and that training should be provided in a manner and language that all employees can understand. Additional ways to address this include:

• Training employees to be knowledgeable about MSDs, how to recognize symptoms, when to report symptoms and how to submit the appropriate documentation.
• Identifying groups of workers who may be more prone to injury. According to Bureau of Labor Statistics, repetitive motion activities posed the most frequent exposure to MSDs and resulted in the most workdays missed (median 18 days).
• Addressing the issue of increasing diversity in the workplace by developing training programs to help workers overcome cultural and language barriers.
• Conducting studies of the work environment to identify unique site-specific risk factors. Train employees to become aware of risk factor so that injuries are prevented.
• Partnering with health and safety organizations or academic institutions to help identify hazards and offer control/prevention solutions.

Occupational and environmental health nurses are key players in the early identification, assessment, treatment and referral of MSDs, helping employers reduce their healthcare costs and improving the bottom line through increased employee productivity, fewer disability claims and improved absentee rates. AAOHN appreciates the opportunity to provide input on this issue. As always, we will continue to support OSHA in promoting a safe and healthful work environment. We would welcome the opportunity to elaborate on the points outlined in this document. Please feel free to contact us at 919-966-0979 for clarification or additional information.

Sincerely,

Susan A. Randolph, MSN, RN, COHN-S, FAAOHN
President, AAOHN

cc: AAOHN Board of Directors
     Ann R. Cox, AAOHN Executive Director