March 29, 2004

Ms. Kemberly M. Ladner
2595 V-Bar Road
Kiln, MS 39556

Dear Ms. Ladner:

Thank you for your June, 2003 letter to the Occupational Safety and Health Administration (OSHA) requesting guidance on limits as to how much weight people are allowed to lift. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any situation not delineated within your original correspondence. Your situation and question are paraphrased below followed by our answer. Please excuse the delay in our response.

Issue: When applying for a position with a local ambulance service, potential employees are required to perform certain physical tests, the last of which is carrying a 160-pound weight up and down five flights of stairs three times.

Question: Is there a policy or guide which states the maximum weight a person may lift?

Reply: OSHA does not have a standard which sets limits on how much a person may lift or carry. However, a sister agency, the National Institute for Occupational Safety and Health (NIOSH), has developed a mathematical model which helps predict the risk of injury based on the weight being lifted and accounts for many confounding factors. The model is based on previous medical research into the compressive forces needed to cause damage to bones and ligaments of the back.

NIOSH has shown through research that a lifting index greater than 3.0 can clearly be linked to an increased risk of back and other injuries. Based on the conditions you described, and assuming ideal conditions for grip, twisting and the other factors in the equation, the NIOSH Lifting Equation gives a lifting index of 3.1. This would classify the lift as a highly-stressful lift and would indicate that nearly all workers would be at an increased risk of injury when carrying 160 pounds. The Applications Manual for the Revised NIOSH Lifting Equation can be found on the NIOSH website listed below. It should be noted however, that the NIOSH criteria are not mandatory.

While OSHA does not have a standard written specifically for the problem you raised, employee exposure to hazards related to heavy lifting and back injuries can be addressed under Section 5(a)(1) of the OSH Act, commonly referred to as the General Duty Clause. The General Duty cause states that:

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 practical terms, the General Duty Clause says that if an employer knowingly exposes their employees to a recognized hazardous condition, then that employer may be in violation of the OSH Act.

If you would like more information on lifting hazards both OSHA and NIOSH have information on their respective web sites which can be found at:

OSHA: www.osha.gov/SLTC/ergonomics/index.html
NIOSH: www.cdc.gov/niosh/topics/ergonomics/default.html#lift

For further information on the protection of employees, you may wish to contact OSHA at the Jackson, Mississippi Area Office. The Jackson Area Office may be reached at:

Jackson Area Office
3780 I-55 North, Suite 210
Jackson, Mississippi 39211-6323
Phone: (601) 965-4606

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 letters 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 http://www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202)693-2190.

Sincerely,


Richard E. Fairfax, Director
Directorate of Enforcement Programs