Standard Interpretations - Table of Contents
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

June 15, 2000

Ms. Alice Freund
Health and Safety Advisor
Service Employees International Union
50 Charles Lindbergh Boulevard, Suite 602
Uniondale, New York 11553-3650

Dear Ms. Freund:

Thank you for your December 3, 1999 letter to the Occupational Safety and Health Administration (OSHA) requesting a "written opinion from OSHA on whether ... working on your knees in a nursing home is unsafe."

You are specifically concerned with the use of mattresses placed on the floor or very low beds that are not height adjustable. This is done to reduce residents' risk for falling out of bed. Employees who care for residents placed close to the floor perform a number of work tasks. These tasks include, but are not limited to:
  • administering medications,
  • turning and lifting residents,
  • changing linens and clothing, and
  • transferring residents to chairs and other devices.
Biomechanically, these tasks require the employee to kneel, bend over the resident and use primarily the upper body for reaching/moving/lifting a resident located on a mattress which is near to or directly on the floor. Awkward trunk postures while lifting have been associated with an increased risk for the development of back injuries.

There are a number of controls that have been success