August 22, 2003 OSHA Docket Office
Docket No. GE2003-1
Room N-2625, U.S. Department of Labor
200 Constitution Ave., NW
Washington, DC 20210
Re: Draft Ergonomics for the Prevention of Musculoskeletal Disorders: Guidelines for Retail Grocery Stores
General Comments
In general, the draft guidelines contain a great deal of useful information. They focus on various solutions that have been implemented by retail grocery stores and 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 grocery store 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.
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Prevention: Any ergonomics strategy should be designed to assist employers in identifying safety hazards and correcting them before injury or illness occurs.
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Clarity: It is important for guidelines to be clear so that employers can easily understand the benefits of preventing MSDs to workers.
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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 retail grocery stores.
Specific Comments
Retail grocery stores 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:
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Encouraging employees to report problems without fear of reprisal so that the disorder may be addressed prior to a disabling condition occurring.
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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.
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Rotating workers so they perform jobs that use different muscle groups, thus keeping muscle groups from being overworked.
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Recognizing the occupational and environmental health nurse as a key player in the identification, assessment, treatment and referral of MSDs, thus lowering employer healthcare costs and improving the bottom line through increased employee productivity, fewer disability claims and improved absentee rates.
The guidelines provide useful checklists based upon risk factors within grocery stores. However, some guidance is needed on what is considered heavy. We recommend the following:
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:
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Training employees to be knowledgeable about MSDs, how to recognize symptoms, when to report symptoms and how to submit the appropriate documentation.
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Identifying groups of workers who may be more prone to injury. According to Bureau of Labor Statistics, MSDs among stock handlers and baggers were up 14.5 percent in 2001. Furthermore, repetitive motion activities such as scanning groceries posed the most frequent exposure to MSDs and resulted in the most workdays missed (median 18 days).
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Decreasing language barriers by developing training programs so that workers may adequately comprehend and better understand the guidelines. In 2001, injuries and illnesses among Hispanic workers were up 3.2 percent from 2000.
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
