July 10, 1985

The Honorable Rod Chandler
House of Representatives
Washington, D.C. 20515

Dear Congressman Chandler:

We are pleased to answer the questions you raised in your letter of June 13. The questions and answers are as follows:

1. What action if any, has DOL and/or OSHA taken on the safe use of video display terminals?

The Department of Labor, Departmental Safety and Health Committee, has proposed a policy for employees which is intended to primarily reduce work fatigue and eye strain from use of VDTs. The policy, when fully implemented, will:

• Provide VDT units with adjustable tables and chairs. (Acquisition and installation of such equipment is underway.)
• Have proper placement of units so lighting will be sufficient and operators will be protected from glare. (This is also being implemented.)
• Provide rest breaks so visual fatigue and/or muscular tension will be at a minimum. (Operators have rest breaks as needed.)
• Have visual testing for VDT operators before begin- ning such work and have periodic eye examinations. (Such a formalized program has not been started.)
• Institute a Department program to increase DOL super- visory and employee awareness of proper VDT usage. (This program has been inaugurated in some parts of DOL.)
• Keep abreast of developments and seek expert advice from leaders, such as National Institute for Occupa- tional Safety and Health (NIOSH).
  
  OSHA has followed the research studies made by NIOSH. Testimony before the Subcommittee on Health and Safety, Committee on Education and Labor, by the Director of NIOSH included these observations:
• VDTs are not a source of dangerous radiation.
• There is some evidence VDTs can increase both physical and emotional stress.
• Although NIOSH did not see any physiologic mechanism whereby VDTs could impair reproductive functions, as yet they do not have the information to definitely rule out this possibility. A major epidemiologic study is being inaugurated by NIOSH to answer this question.

2. What is the total number of members serving on FACOSH?

There are sixteen members on FACOSH. A membership roster is enclosed.

2(a) How many of the FACOSH members are agency head representatives?

2(b) How many of the FACOSH members are union representatives?

3. Did FACOSH recommend the use of FECA data in lieu of FARS data?

FACOSH endorsed the proposed change from FARS to FECA at its meeting on January 12, 1983.

4. If so, what was Mr. Blaylock's position on the use of FECA data?

Mr. Blaylock seconded the motion to adopt the FECA data -

see page 54 of the enclosed transcript of the January 12, 1983, FACOSH meeting.

5. If there was discussion of this at FACOSH please supply the subcommittee with copies of the pertinent transcript pages.

There was discussion on this subject as shown in pages 45 through 54 of the January 12, 1983, meeting, tran- script enclosed. Also, enclosed is a copy of the Sub- committee on Federal Accident Reporting System's report proposing the change from FARS to FECA.

6. The AFGE charged that FECA data for targeting Federal agencies should not be used because FECA focuses on compensation, not prevention and the data is inadequate for illness recognition. What is your response to these allegations?

Neither FARS nor FECA data provide statistical informa-

tion that identifies causes and the results of injuries. The FECA data does provide the total numbers of cases and compensation costs. It is true that current FECA data combines injuries and illnesses into a total case figure. The Office of Workers' Compensation Programs has stated, however, that illnesses comprise about three percent of the total compensation cases. We believe, therefore, that the use of total cases and compensation costs to pinpoint agencies or establish- ments which show increases is a fair method of targeting installations in need of help. Additionally, compensa- tion figures from OWCP are required to be furnished under the OWCP Act subject to penalties for misreporting. OSHA is working with OWCP to adapt compensation reporting data to include causal data which will increase its use- fulness as a prevention tool.

7. How was FARS data arrived at and how does that differ from FECA data?

FARS data was prepared by the individual agencies as summaries of injuries/illnesses, as shown on logs maintained by the agencies, and there was no way to verify its accuracy. FECA data is determined by the number of compensation claims filed with OWCP and the costs are those which OWCP accumulates and charges back to the agencies.

We appreciate your interest in the Federal safety and health program.

Sincerly,



John B. Miles, Jr.
Director
Directorate of Field Operations

1. What action if any, has DOL and/or OSHA taken on the safe use of video display terminals?

2. What is the total number of members serving on FACOSH?

2(a) How many of the FACOSH members are agency head representatives?

2(b) How many of the FACOSH members are union representatives?

3. Did FACOSH recommend the use of FECA data in lieu of FARS data?

4. If so, what was Mr. Blaylock's position on the use of FECA data?

5. If there was discussion of this at FACOSH please supply the subcommittee with copies of the pertinent transcript pages.

6. The AFGE charged that FECA data for targeting federal agencies should not be used because FECA focuses on compensation, not prevention and the data is inadequate for illness recognition. What is your response to these allegations?

7. How was FARS data arrived at and how does that differ from FECA data?