OSHA published a comprehensive ergonomics standard that was subsequently rescinded by Congress using the Congressional Review Act (CRA). Since that time, OSHA has been prohibited from passing another ergonomics standard. OSHA’s current approach is to publish ergonomic guidelines, which are not legally enforceable, for industries with high incidence rates of MSDs and CTDs.
What is your opinion of OSHA’s current approach to ergonomic issues in workplaces? Can you propose an approach that you believe would better address ergonomic issues?
Description of the environmental problem and other social concerns that are being addressed by the policy (i.e. the policy goals).
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When functioning in a highly charged political environment as well as being subject to congressional approval for rule and law changes. The reality is OSHA can only make recommendations and let lawmakers decide on mandatory versus voluntary or recommended practices. Dudley (2001) argues that OSHA’s research was inadequate and did not provide both the numbers of musculo-skeletal disorders (MSD’s) and how the program would reduce those injuries as well as what casts versus saving would occur for businesses. OSHA indicated that businesses were underreporting these types of injuries and if reporting was accurate the number of incidents would be much higher. This likely supports the assumption that these standards will not become law unless additional research could support the true value as well as the true problem.
OSHA’s current enforcement mechanism outside of voluntary compliance is the use of the general duty clause. While this may be effective in some ways it does not give specific requirements as to the violations that should be accepted as law. One way to address the ergonomic issue could be system engineering as well as coordination with other agencies involved in the improvement of ergonomics. The American National Standards Institute (ANSI) is an organization that supports voluntary standards and conformity and has over 270,000 businesses listed as partners and is an international organization (ANSI, 2020). The International Organization for Standardization (ISO) brings together experts to share knowledge and develop voluntary, consensus-based, market relevant International Standards that support innovation and provide solutions to global challenges (ISO, 2020).
I point out these organizations since they could follow a model of either an Alliance Program or an OSHA Strategic Partnership Program with OSHA. Understanding that many companies conduct business internationally or buy equipment from foreign partners, starting to take on more of a global awareness could create an efficiency for OSHA. It also has the benefit of bringing in experts who work in the field of ergonomics and have credibility and insight to develop standards. From earlier studies it was noted that OSHA can be slow to react to changing environments and outside influences. Expanding this into a Voluntary Participation Program (VPP) begins to place even more onus on businesses for compliance. This not only frees up OSHA personnel involved in inspections but opens up another potential model of accreditation. Many accreditation agencies utilize other agencies as checkpoints for evaluation of their current model. Accredited organizations have been through a process of self-evaluation and have been inspected and reviewed by other agencies who were already accredited. Accreditation can be used to evaluate best business practices, seek favorable insurance and financing options, and also keep an organization competitive among its peers. This wholly funded by participating organizations or grants and keeps OSHA directly out of the development process but still engaged as an inspection and enforcement agency as needed.
ANSI. (n.d.). About ANSI. Retrieved from https://www.ansi.org/about_ansi/overview/overview?menuid=1
ISO, (n.d.). About us. (n.d.). Retrieved from https://www.iso.org/about-us.html
Dudley, S. E. (2001). The Benefits and Costs of OSHA’s Proposed Ergonomics Program Standard. Journal of Labor Research, 22(1), 95. Retrieved from http://eds.b.ebscohost.com.libraryresources.columbiasouthern.edu/eds/detail/detail?vid=11&sid=e473a82f-bde6-41c9-b2fb-e9e33fdd64f4%40pdc-v-sessmgr03&bdata=JnNpdGU9ZWRzLWxpdmUmc2NvcGU9c2l0ZQ%3d%3d#AN=4031454&db=edb