March 18, 2024

Dr. Emily Lewis
Department of Radiology
University of Wisconsin School of Medicine and Public Health
Madison, WI 53792
 

Dear Dr. Lewis:

Thank you for your inquiry to the Occupational Safety and Health Administration's (OSHA) Directorate of Enforcement Programs, wherein you expressed your concerns about sonographer exposure to occupational ergonomic hazards and the high rates of injuries and musculoskeletal disorders (MSDs) among these essential healthcare workers. In your letter dated October 10, 2023, you identified yourself as a professor emerita in the Department of Radiology within the School of Medicine and Public Health at the University of Wisconsin, and you have co-authored this letter with Dr. Mark Kliewer, a colleague and professor emeritus, within the same department.

Background: You provided a summary of ergonomic hazards that ultrasound sonographers are exposed to, including recent studies, MSD injury rates, and recommendations from organizations, including the Society of Diagnostic Medical Sonography (SDMS), the American Institute of Ultrasound in Medicine (AIUM), and the National Institute for Occupational Safety and Health (NIOSH). These studies outline the types of ultrasound sonography performed, the associated ergonomic hazards and injuries, and recommendations of corrective actions. Examples of corrective actions include administrative controls such as reducing the scanning time and number of patients evaluated each day, and engineering controls that include assistive technology, including two-hand transducers and robotic technology. You also provided references predicting the increasing demand for ultrasound sonographers and likely staffing shortages. In addition, you noted that ultrasound equipment manufacturers currently produce and market the equipment that poses ergonomic risks to sonographers, profit from the increasing demand for ultrasound diagnoses and equipment, and do not have incentives to research and develop engineering controls that could reduce sonography-related ergonomic hazards.

Based on this information, you requested that OSHA re-investigate the MSD hazards facing sonographers and issue a Hazard Alert to U.S. hospitals, clinics, and ultrasound equipment manufacturers. You also requested that OSHA conduct new investigations and issue citations and develop occupational exposure standards for sonography. Finally, you requested that OSHA establish a nationwide goal to reduce the MSD injury rates of ultrasound sonographers within a targeted timeline, which should create an economic incentive for the healthcare industry to implement corrective actions, and an incentive for ultrasound manufacturers to develop improved equipment design and technologies.

Response: The potential for ergonomic risks associated with medical sonography are recognized. OSHA addresses this topic in the agency's online Hospital e-Tool (https://www.osha.gov/etools/hospitals/clinical-services/sonography). Additionally, your letter indicates research and recommendations by both NIOSH and SDMS for needed advancements in technology, such as improved ergonomic designs of ultrasound equipment and sonography workstations, reductions in the number of patients sonographers evaluate, and reductions in specific hazardous procedures such as one-handed transducer sonography.

While OSHA does not have a specific ergonomics standard, employee exposure to hazards related to repetitive motions and awkward postures that cause MSDs may be addressed under Section 5(a)(1) of the Occupational Safety and Health (OSH) Act, commonly referred to as the General Duty Clause. The General Duty Clause states:

Each employer -- shall 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...

In addition, OSHA has ongoing enforcement activities in the healthcare industry, including hospitals, outpatient clinics, and long-term care facilities, which may also include workers in areas that provide imaging services (x-ray, MRI, sonography).

For more information, OSHA has a safety and health topics webpage for ergonomics, which can be found at: https://www.osha.gov/ergonomics. Also note, that topics page includes industry and task-specific solutions, including the hazardous healthcare tasks of sonography and patient lifting. Common ergonomic hazards faced by sonographers, as well as recognized controls and work practices are detailed in the online Hospital e-Tool. Additionally, OSHA has a webpage (https://www.osha.gov/alliances/sdms/sdms) describing its concluded alliance activities with the SDMS, and OSHA has posted a copy of the 2021 SDMS industry standards for sonography. OSHA also has an ongoing alliance ambassador relationship with The Joint Commission, which has recently focused on the ergonomic hazards associated with patient lifting in healthcare, as well as other hazards facing healthcare workers (https://www.osha.gov/alliances/jcaho/jcaho).

Accordingly, OSHA will continue to enforce protections against workplace ergonomic hazards by means of the General Duty Clause, and the agency recognizes the risks associated with medical sonography. We appreciate your providing this additional information on the unique hazards faced by sonography workers. In response to your request, OSHA will consider your suggestion for the development of a Hazard Alert about the ergonomic hazards in sonography. OSHA will also add links to the industry guidance you recommended (SDMS, AIUM) to its topics page for ergonomics. Additionally, OSHA will incorporate the information you provided into our compliance officer training as well as in our enforcement and outreach efforts going forward.

With respect to inspection activities, please be advised that all employees have the right to file a confidential safety and health complaint and request an OSHA inspection of a workplace if the employee believes there is a serious occupational hazard in the workplace, online at (https://www.osha.gov/workers/file-complaint.) In addition, all employees have the right to file a whistleblower complaint with OSHA if they believe their employer retaliated against them for exercising their rights as an employee under the whistleblower protection laws enforced by OSHA, accessible here (https://www.whistleblowers.gov). In addition to filing online, workers may also file confidential health and safety complaints, and retaliation complaints, by mail, fax, and in person by visiting their local OSHA Area office.

Finally, since you are a faculty member at an academic institution, we would also like to advise you that OSHA administers the Susan Harwood Training Grant Program. Applicants may be either nonprofit organizations or state and local government-supported institutions of higher learning. If your institution meets this qualification, you or colleagues might consider applying for a grant to develop occupational safety and health training materials for sonography workers. See https://www.osha.gov/harwoodgrants.

Thank you for your interest in occupational safety and health. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.

Sincerely,

Kimberly A. Stille, Director
Directorate of Enforcement Programs