Our Chapter and ASSE consider this issue to be of primary significance. It positions health care professionals as potentially being able to provide consultation on ergonomics without regard for their occupational safety and health professional background. As proposed, the standard may force some organizations to focus their primary attention to ergonomics instead of enhancing their overall safety and health program. The standard should be applicable to all employers and implemented during the same time frame. Failure to do so creates a category of second-class citizens for the employers working in industries exempt from the standard.
All employees have the same right to a safe workplace.
The standard should describe the basic tenets and best practices necessary for successfully developing and managing an effective ergonomic program. Medical Management - The language addressing medical management is a serious concern, and we suggest it be removed in its entirety. HCP not trained in occupational field creates potential for misdiagnosis and mismanaged WMSDs OSHA position here is inconsistent since it places great faith on HCP as 3rd party reviewers, but continues to express concern with the integrity and honest of safety consultants. Language in proposed rule potentially establishes HCP as defacto workplace ergonomic consultants. Qualified Safety and Heath professionals should have been cited as providers.