September 14, 1989

The Directorate of Technical Support was asked on August 22, by the Office of Field Programs to provide a technical position on employment screening, job rotation, and light duty for cumulative trauma disorder (CTD) risk factor abatement.

1. The term "baseline health surveillance" is suggested instead of "pre-employment screening" for the alleged variable description of future citations. The purpose of baseline surveillance is to establish a reference point from which changes in health status may be evaluated. Both OSHA and NIOSH recognize that there is no established scientifically valid way to identify individuals who may develop CTD in the future.

2. Job rotation is a method of reducing the duration of a given set of CTD risk factors. The job rotation should be designed in conjunction with an individual who is qualified to evaluate the additive effect of a set of risk factors for each job within a work position. This may be a way of offering some interim protection until more effective engineering and work method changes can be implemented.

3. "Light duty" is a term which is used synonymously with "restricted activity" to indicate an assignment with reduced stress from risk factors.

[Corrected 10/22/2004]

August 22, 1989

The attached letter from Deborah Berkowitz transmits her concerns about certain aspects of recent cumulative trauma disorder citations issued by OSHA. She specifically addresses pre-employment screening, job rotation, and light duty. Please consider this point raised by Ms. Berkowitz and respond to us with your position within 30 days. Please reference OFP #1589.

Attachment

June 15, 1989

Mr. Leo Carey
Director, Office of Compliance
OSHA
200 Constitution Avenue, NW
Washington, DC 20210

Dear Leo:

As a follow up to our phone conversation, I want to restate our concern regarding some of the abatement measures included in recent OSHA cumulative trauma hazard citations.

In specific, many recent citations (see attached for the most recent example) contain language requiring or suggesting employers to conduct pre-employment screening of workers. This gives the appearance that OSHA is suggesting that employers screen and weed out all employees susceptible to CTD's.

I doubt this is what OSHA was intending. Especially since there are no pre-disposing factors for CTD's, except of course if a worker was previously diagnosed. However, this gets into state laws on discriminating against the handicapped.

This language should be excluded from citation language unless OSHA can assign a use to this exam. We feel strongly that this language should be omitted for cumulative trauma hazards.

I suggest you contact Dr. Barbara Silverstein or Dr. Larry Fine for more information regarding this item.

The other item of concern to us is the reliance of "job rotation" as a potential solution in these citations. In meatpacking, for example, many of the citations have included this as an abatement measure. However, unless the rotation is designed by an ergonomist - so that one is sure that different muscle groups are being used, and unless there is a provision for rate retention, job rotation can not only further injure workers, but they could be penalized because their job causes CTD's. I have enclosed a letter regarding job rotation for your information.

Furthermore, most plants have few "light duty" jobs that must be preserved for injured workers. If these are put in a job rotation program, then you have limited the ability for the plant to fully implement a sound medical management program.

We strongly urge the agency to omit job rotation as a recommended solution.

As we stated in Congressional testimony last week, it is imperative that OSHA communicate with its area offices on the kinds of abatement prescribed in ctd citation. We urge you to communicate swiftly with your area offices on this important issue.

Sincerely,


Deborah E. Berkowitz, Director
Occupational Safety and Health Office
Collective Bargaining Department