February 13, 2015

Ms. Christine Rechner
522 Bonniebrook Ave
Mundelein, Illinois 60060

Dear Ms. Rechner:

Thank you for your November 23, 2014 letter to the Occupational Safety and Health Administration (OSHA). Your letter has been referred to the Directorate of Enforcement Programs for an answer to your specific question about regulations that cover knee health and safety of veterinary technicians and assistants. This response constitutes OSHA's interpretation only of the question discussed and may not be applicable to any situation not delineated within your original correspondence. Your paraphrased scenario and question are below, followed by our response.

Scenario: Veterinary technicians and assistants are required to restrain pets during exams. Restraining pets requires these employees to squat or kneel for a large portion of the day. The employees may also need to lift heavy pets.

Question: Are there OSHA requirements that would protect employees from knee, ankle or back injuries associated with prolonged squatting, kneeling or lifting?

Response: OSHA does not have any specific requirement that would limit the amount of time an employee is required to work in an awkward posture, such as squatting or kneeling. Nor does OSHA have a personal protection requirement for work that requires squatting or kneeling. However, the absence of an OSHA regulation does not mean that employers can expose an employee to a recognized hazard. Section 5(a)(1) of the Occupational Safety and Health Act of 1970 requires employers to furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees (also known as the general duty clause).

We agree there are awkward postures and contact pressures experienced by many veterinary technicians as described in your letter. The ergonomics literature has identified squatting and kneeling as a source of musculoskeletal disorders when there is cumulative exposure of 4 or more hours daily. OSHA believes that a safe workplace is a benefit to both the employee and employer, because eliminating ergonomic risk factors eliminates injuries and saves money.

The American Veterinary Medical Association has provided guidelines for ergonomics. Their guidelines can be found at [https://www.avma.org/KB/Policies/Pages/Veterinary-Ergonomic-Guidelines.aspx]. The guidelines include a chart describing ergonomic risk factors that lead to musculoskeletal disorders and examples of tasks that have those risk factors.

However, the guidelines do not recommend controls. OSHA believes there is a hierarchy of controls that starts with eliminating the ergonomic risk. For those risks that cannot be eliminated, the hierarchy of controls, in order of most to least effective is: engineering; administrative; work practices; and personal protection equipment (PPE).

OSHA agrees that PPE for kneeling reduces contact pressure. PPE does not reduce the risk related to the awkward posture, as you described in your letter. Regarding the use of back belts, OSHA and the National Institute for Occupational Safety and Health (NIOSH) have both taken the position that back belts are not appropriate PPE for the back when an employee is lifting. Lifting risk factors can be assessed using the NIOSH lifting equation. Lifting assessments using the NIOSH equation have been simplified with tools developed by several states. The Ohio Bureau of Workers’ Compensation has a calculator for assessing risk levels associated with lifting various weights, which is available at [https://ergo-plus.com/wisha-lifting-calculator-guide/]. Similarly, the Washington State Department of Labor and Industries has developed a calculator for analyzing lifting tasks, based on the NIOSH lift equation, and is available at lni.wa.gov/wisha/ergo/evaltools/ergocalc.pdf.

If you would like more information on ergonomic risk factors and associated hazards, both OSHA and NIOSH have information on their respective websites, which can be found at:

OSHA: www.osha.gov/SLTC/ergonomics/index.html

NIOSH: www.cdc.gov/niosh/topics/veterinary/physical.html

Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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 scenario and question 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 www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.

Sincerely,

Thomas Galassi, Director
Directorate of Enforcement Programs

[Corrected 5/13/2019]