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American Meat Institute Urges OSHA to Withdraw Proposed Ergonomic Standard

Thursday, March 2, 2000

The American Meat Institute (AMI) today urged the Occupational Safety and Health Administration (OSHA) to withdraw its proposed ergonomic standard in favor of voluntary programs that are flexible and industry-specific, like the one adopted by the meat industry and OSHA in 1990.

AMI made its statement in comments submitted to OSHA on the proposed ergonomics standard, which was published in the November 23, 1999, Federal Register. The North American Natural Casing Association joined AMI in the comments.

"AMI strongly supports the practice of ergonomics. Ergonomics is used most effectively as a proactive, prevention-oriented process for safety and productivity improvement," said AMI Senior Vice President of Regulatory Affairs and General Counsel Mark Dopp.

The meat industry worked cooperatively with OSHA in developing the "Ergonomics Program Management Guidelines for Meatpacking Plants," which were issued in August 1990, and have been used for nearly 10 years. As a result, between 1990 and 1997, total injury and illness incidents in the industry declined by 31 percent; lost time incidents declined by 44 percent and lost work day incidents declined by 17 percent.

But OSHA’s proposed standard "is excessively broad, is written in very subjective and vague terms, and will lead to confusion and abuses of interpretation. It also is not performance based because it lacks factual criteria on which to measure performance," AMI said. "Additionally, the proposal approaches the practice of ergonomics from a reactive – rather than preventive – perspective. Consequently, the proposal will shift application (and resource) focus to compliance, at the cost of efforts presently dedicated to prevention."

Scope Extends Beyond Ergonomics

AMI noted that worker safety programs historically have focused on the prevention of carpal tunnel syndrome and employershave worked to assess what jobs and movements could contribute to the disorder. OSHA’s proposal would require employers to consider the much broader class of musculo-skeletal disorders or MSDs (this would include general back pain) and all potentially contributing factors.

Given the fact that the medical establishment says 80 to 90 percent of working people will experience back pain during their work lives, it cannot be assumed that back pain is directly related to work. If employers are required to find ways to prevent the broad class of MSDs, virtually every job could fit the description of a "problem job" under the rule. Employers would become
responsible for problems over which they have little or no control. "Packing hot dogs may contribute to an MSD caused by guitar playing," the comments said.

Furthermore, carpal tunnel research indicates that physiological predisposition is often the primary factor for developing CTS. Yet under the proposed rule, virtually any human movement in a workplace could be deemed a contributing factor.

AMI also objected to the many ambiguities in the proposal. To illustrate, the Institute detailed a list of 26 terms and phrases used throughout the proposal that are unclear, subject to very broad interpretation and destined to cause confusion and conflict for plants in implementation and for inspectors attempting to enforce the regulation. These include, "considerable," "too high or too low," "periodically," "heavy," "prompt and promptly," "too large or too small," "long time," and "reasonably anticipated."

Economic Impact Grossly Underestimated

Calling OSHA’s economic conclusions about the costs of the rule "startling," AMI said that the agency’s final cost should haveprompted re-evaluation before issuing the proposal.

For example, the rule estimates a cost of $700 per workplace to implement the regulation and $150 per "problem job" fixed. A common "fix" used in meat packing plants and many other industries is the use of adjustable workstations framed by stainless steel pipe at a cost of $15-20 per linear foot. Other common meat industry fixes include adjustable platforms, which cost at least $200, and mechanized workstations, which cost $3,500-$4,000. Wheeled carts are used to transport equipment, boxes and even disabled livestock in some cases. Plastic carts cost nearly $300 while stainless steel carts cost $525.

The proposal also states that 15 percent of all MSDs will lead to job analyses requiring an outside consultant. A typical rate for a certified ergonomist is $1,200 to $1,5000 per day. These costs are not considered in OSHA’s cost estimates, nor are the enormous costs of facility reconfiguration that may be required to comply with the regulation.

"If the agency’s goal is to effect a substantive improvement in safety, voluntary ergonomics guidelines have a proven record of success and will avoid the many problems identified with the proposal," AMI said.

A complete copy of the comments may be found on AMI’s web site at http://www.meatami.org.

AMI represents the interests of packers and processors of beef, pork, lamb, veal and turkey products and their suppliers throughout North America. Headquartered in Washington, DC, the Institute provides legislative, regulatory and public relations services, conducts scientific and economic research, offers marketing and technical assistance and sponsors education programs.

For more information contact:
Janet Riley
Vice President, Public Affairs
James Ratchford
Manager, Public Affairs

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